CONSEQUENCE MANAGEMENT POLICY FOR SAFETY

Safety is one of the Core Values of TP Central Odisha Distribution Limited (TPCODL). In line with the same TPCODL is
committed towards providing a safe work environment to all the stakeholders.

TPCODL strongly believe that employees are its greatest asset, and it is committed to ensure their overall safety.This is
evident in the various business processes and work procedures that have been laid down in theorganization. In order
to achieve this, world class safety standards and procedures have been implemented for establishing Safety culture and
inculcating safe behavior among the employees.

Consequence Management Policy for Safety is to establish a framework for disciplinary decision making thereby
ensuring a fair and transparent process for initiating such actions, which are intended towards establishing and
maintaining safe work environment. This Policy also ensures that while laying down an approach, it does not overlook
the intent behind any safety deviation or malpractice. The objective of the policy is to ensure that each employee is
committed to Safety and at the same time it gives them the independence to take decisions as per the necessary process
and operation.

This version of the policy is applicable to all employees of TP Central Odisha Distribution Limited (TPCODL).

CONSEQUENCE MANAGEMENT POLICY FOR SAFETY for

Doc Title: TPCODL
Document No: TPCODL – HR – CMPS - 2.0

Version No: Version 1 .0

Issued By Issue Date Revised Date Reason for Revision

Head – Business Excellence 1st April 2023 1st April 2023 New Release
 1. Objective
The objective of the Consequence Management Policy for Safety is to establish a framework for
disciplinary decision making thereby ensuring a fair and transparent process for initiating such actions,
which are intended towards establishing and maintaining a safe work environment. This document
discusses the disciplinary actions in response to safety misconducts or violations as described in the
Industrial Employment Standing Orders Act 1946 or such other Acts/Rules applicable to the Company.

2. Scope

The Consequence Management Policy for Safety is applicable to all employees of TPCODL hereinafter
referred to as 'Company' / 'Organization' in this policy.

3. Definitions
3.1 Human Error

An unintentional action or decision in judgment. General agreement that such an error is not through
a deliberate plan. Human error can be broadly categorized as slips, lapses (skill-based error)) and
mistakes. Slips may be skill-based, actions not as intended, the employee being unaware and task-
execution failures. Lapses are unconscious mental errors. Mistakes are due to a lack of knowledge and
skill.

3.2. Safety Violation:

i. Any act and/or condition which is inconsistent with the fulfillment of expressed or implied
requirements of the Company’s Safety Code of Conduct, Safety Policy/ Procedure, Safety Principles,
legal requirements, or Any critical activities in a High-risk Zone/area identified by divisions/sites.
ii. Any breach of an expressed or implied duty on part of the employee.

The following illustration shows a clear distinction between error and violation.

(Reference: Reproduced from Reason, J. T. (1990). Human Error)

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 3.2.1. Safety Violation not resulting in an incident
Safety Violations that have the potential of loss of asset/Property or financial loss or
potential of causing injury/Occupational illness.
3.2.2. Safety Violation resulting in an incident
Safety Violations that have caused loss of asset/Property or financial loss or causing
injury/Occupational illness.
3.2.3. Intent behind the violation
Intent behind the safety violation, at the employee level, is graded in three degrees. This
is important to establish in cases where there is a bonafide error and the employee under
investigation can be counseled and trained on corrective action.
Table -1

Level of Intent Description

I-1 Employee lacks in knowledge of accompanying hazards and associated risk

controls.
Employee recognizes accompanying hazards and associated risk controls, but
I-2 due toconstraints does not apply risk controls.
Employee has full knowledge of accompanying hazards and associated risk
I-3
controls, yetwillfully violates the same.

3.2.4. Severity (Loss/Potential loss ):

Severity of loss arising from the violation is graded in four degrees:

Table -2

Level of
Description
Severity

S-1 S-1: Minor / potential loss category- where the resulting loss/potential loss or Incident is
minor e.g., Physical discomfort/ Noticeable and requiring First Aid or slight health problem
or/and Slight property damage up to Rs. 5 Lakh
S-2: Moderate / potential loss category - where the resulting loss/potential loss or
S-2
Incident is moderate e.g., Temporary Disability (MTC/ RWDC) or health problem causing
MTC/RWDC or/and damage more than Rs 5 Lakh but less than 25 Lakhs
S-3: Serious / potential loss category - where the resulting loss/potential loss or Incident
S-3 is serious e.g., Grievous injury and/or Partial Permanent Disability (PPD) with or without
major property damage/Partial Permanent Disability/ Lost workday case (LWDC) or major
health problem causing LWDC or/and Major damage more than Rs 25 Lakhs but less than
1.25 crore
S-4: Extremely Serious / Hi-potential loss category - where the resulting loss/hi-
S-4 potential loss or Incident is very serious e.g., Fatal/ Total Permanent Disability (TPD) or
severe health problem or/and major property damage/Severe damage more than Rs 1.25
crore

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 3.2.4.1 The degree of the safety violation would be decided by the combination of the
Intent and the Severity of theoutcome of the safety violation (as per Intent – Severity
matrix- see matrix at table 4).
3.2.4.2 Degree of the Safety Violation: Violation of any clause of Safety Code of Conduct
(SCoC) will be treated as Medium degree V3.
3.2.4.3 Accountability of any safety violation will lie with both the Supervisor and
employee concerned.

Table -3
Degree of Violation Description
V-1 Low Degree
V-2, V-3 Medium Degree
V-4 High Degree
3.2.5. Intent – Severity Matrix

Table-4

DEGREE OF VIOLATION (V)

I-3 V-2 V-2 V-3 V-4

INTENT (I)

I-2 V-1 V-2 V-2 V-3

I-1 V-1 V-1 V-2 V-2

Severity(S) S-1 S-2 S-3 S-4

Consequence Management- Post Safety violation:

It is the fundamental duty of every employee to report the unsafe act/behavior / condition of any
safety violation to reporting manager and concerned area in charge immediately and to STOP unsafe
work as required.

Step 1 – Fact Finding

CEO TPCODL shall form incident Investigation team as per company’s incident investigation
procedure to establish the facts related to the incident including the circumstances leading to the
safety violations (In case of Fatality, one senior member of chief level other than Discom where fatality
occurred) to be chairman of committee. Subsequently based upon investigation report special Enquiry
Committee/ Enquiry Committee to formed to establish level of intent, severity, and degree of violation.

Step 2 – Evaluation
Intent behind the violation
In determining the appropriate category (i.e. I-1, I-2 or I-3) of the Intent behind the violation,

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 special Enquiry Committee/ Enquiry Committee shall consider the following factors:
a. Reasons (Individual / System related)
b. Experience of employee (position level, training, past exposure)
c. Repetition of similar act if any

Loss/Potential loss (Severity)

In determining the appropriate category (S-1, S-2, S-3 or S-4) of the loss and/or potential loss arising
from the violation, the special Enquiry Committee/ Enquiry Committee shall consider the following
factors:
a. Facts established
b. Severity of loss or immediate potential loss
c. Deficiency in system or equipment that contributed to the loss, if any

Responsible person, reporting officer and reviewing officers shall be evaluated separately as per Fair
and Just culture flow chart shown below:

Step 3 - Recommended Disciplinary Action

Based on step 2:

a. For the erstwhile employees of TPCODL who are covered under the Company's/ OSEB
Standing Orders or their existing Service Rules, appropriate disciplinary action will be initiated
in accordance with the provisions applicable thereunder.
b. For all other employees, the CEO shall use the following tables (Table-5) inrecommending the
appropriate disciplinary action:

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 Table- 5:
Disciplinary Action for Safety Violations resulted in Loss/Injury/occupational Illness
Overall Severity
Disciplinary Action
V-1 Verbal Counselling / Advisory Memo /Mandatory safety training as applicable
V-2 Warning Letter / Mandatory safety training as applicable
V-3 Mandatory Unpaid leave from one to five days, with entry into personnel
records
V-4 Stoppage of Increment & Performance pay /Promotion Delay maximum up to 2
yrs. from the date of eligibility

Table-5a : Matrix for action to be taken against the employee and the reporting chain
for safety violation/incident
Degree of Responsible Reporting Reviewing Circle Head /
Violation Employee Officer officer Head Chief
Verbal Counselling Advisory Memo Advisory Memo Nil Nil
V1 /Advisory Memo /Mandatory
/Mandatory safety
training as safety training as
applicable applicable
Warning Letter / Warning Letter Warning letter Advisory Memo Nil
V2 Mandatory safety /Mandatory safety
training as training as
applicable applicable
V3 Mandatory Unpaid Warning letter Warning letter Warning letter Advisory
leave from one to Memo
five days, with entry
into personnel
records
Stoppage of Stoppage of Mandatory Mandatory Warning
V4 Increment & Increment & Unpaid leave Unpaid leave letter
Performance pay Performance pay from one to five from one to five
/Promotion Delay days, with entry days, with entry
/Promotion Delay
maximum up to 2 into personnel into personnel
maximum up to 2
yrs. from the date records records
yrs. from the date of of eligibility
eligibility

4. General Guidelines
a. The Company reserves the right to take the circumstances of the rule breaking / violation into
accountto determine the disciplinary action to be taken.
b. For repeated violations, the next level of disciplinary actions shall be initiated.
c. Multiple injuries in one incident will be treated as most Severity injury in that incident. For example
– In an incident there are three injuries, one S3, second S2 and third S3 severity, in such case this
will be considered as S3 severity incident.
d. Multiple injuries of same severity in one incident will be treated as one level Higher Severity. For
example- In an incident there are three injuries, and all are S2 severity, in such case this will be
considered as S3 severity incident. However, when there are multiple injuries of S4 severity in an
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 incident, such incident will be considered only as S4 severity incident.
e. Disciplinary actions for all Severity shall be decided at CEO Level by an enquiry/special enquiry
committee comprising of the Chief/Head from TPSODL/TOWODL/TPNODL nominated by
Functional Chief, Head – Cluster Safety of Corp Safety and the Head - HR,TPCODL
f. Any order passed after enquiry shall be kept in the employee’s file.
g. It is obligation of every employee to report safety incidents in which they are involved, or which
cometo their notice. Withholding, non-reporting or manipulation of information/data related to
safety incidents is an offence which will be viewed seriously, and strict disciplinary action will be
taken for such an offence.
h. Affected employee can appeal against the application of consequence management through
respective Head- HR which shall be verified by an appellate committee comprising of respective
Cluster chief, CHRO, Chief Safety & Environment. and CEO - TPCODL. Decision take by appellate
committee will be finaland it will be binding on concerned employee.

5. Timelines:

a. For incidents resulted S4 severity, Special Enquiry Committee shall be constituted within two
days of completion and submission of Investigation report by Incident Investigation team to
CEO-TPCODL. Investigation Team shall adhere to Incident Reporting & Investigation Procedure
(TPSMS/GSP/IRI/011) and for timeline of investigation report submission Refer below table. For
all other severity (S1, S2 & S3), Enquiry Committee shall be constituted within two days of the
occurrence to ascertain the level of violations.
b. Enquiry Committee/Special Enquiry Committee shall submit enquiry report with
recommendation within 07 days.

c. Consequence management actions shall be conveyed to concerned Employee subjected to

consequence action. Concerned employee may raise written appeal to appellate committee
within 07 days and Appellate committee should conclude the matter within 7 days.

d. Consequence management actions shall be implemented within 7 days post submission of

enquiry report. In case matter has gone to appellate committee; actions shall be implemented
within 07 days based upon recommendations from appellate committee.

Table-7: (Version 1 .0) Timeline for Consequence Management Actions

SN Key Activity Timeline for S3, S2 & S1 Severity Timeline for S4 Severity
(Days) (Days)
Nos of Days Cumulative Days Nos of Cumulative
for each from Date of Days for Days from
Activity Incident each Date of
Activity Incident

1 Investigation Team formation 02 02 02 02

2 Completion of Investigation 07 09 15 17

3 Special Enquiry Committee/ 02 11 02 19

Enquiry Committee formation

4 Completion of Enquiry and 07 18 07 26

information of concerned
employee for proposed

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 consequent Management
action.

5 Period of appeal 07 25 07 33

6 Consequence Management 07 25 (Total days 07 33 (Total

action implementation where no for non- days for non-
appeal availed. Action appealed case) appealed
Completed case)

7 Review by Appellate committee 07 32 07 40

in case of appeal

8 Consequence Management 07 39 (appealed 07 47 (appealed

action implementation where case) case)
appeal availed. Action
Completed

6. Exceptions
Any exception to this policy requires the prior written approval of the CEO - TPCODL.

7. Roles and Responsibilities

Roles Responsibilities
Employee Report the unsafe act / behavior / condition of any safety violation to
theconcerned authority and to STOP unsafe work as required
CEO-TPCODL  Establish the facts related to the incident including the circumstances

belonging lto the safety violation

 Execute disciplinary action for violation of all Severity

 Member of Appellate committee

Head – Human Resources Execution of disciplinary action and update employee file
Special Enquiry Committee Establishing the fact related to incidents of severity of S4.
Incident investigation committee Investigate the Incident and provide factors responsible for Incident

Head- Cluster Safety/Corp Safety Participate as special enquiry committee member.

President – T&D Member of appellate committee; Recommend disciplinary action for

V4 level; Final approval for execution of disciplinary action V4
Chief Safety & Environment Member of appellate committee
CHRO Member of appellate committee

TPCODL - CONSEQUENCE MANAGEMENT POLICY FOR SAFETY Release Date: April 2023
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