Version: 0.4
Last Amendment:

Nov 2023
Next Review:Nov 2024

Grievance Policy & Procedure
GLB-HR-23-11-INT

Department:

People & Culture
Contact:

jbinnion@keywordsstudios.com

To be read in conjunction with:

CONFIDENTIAL AND PROPRIETARYEXECUTIVE SUMMARY
1.

For any business travel, reason should prevail. People should manage their bookings and expenses
as if it was their own money.

2. We shouldn’t travel if we don’t need to: that’s better for our finances and that’s better for theplanet.
3. Where the Navan platform is available, its usage to manage travel and hotel bookings will bemandatory.
4. Seat reservation options can be flexible depending on your band in the Group, but by default, weshould always try to limit ourselves to economy classes.
5. All travel and expenses need to be approved by your manager. Please do so ahead of booking a newtrip.
6. All exceptions to this policy should be approved by an ExCo member.

Document Title

Document No.

Version

GLB-HR-23-11-INT
Grievance Policy & Procedure

0.4

Last Revision Date

Nov. 13, 23

Page 1 of 5

Document HistoryDateVersion

Description

Author

01/01/2018

0.1

First draft

Gerry Cleary

01/31/2019

0.2

Slight adjustments to structure of verbiage, addition ofAppendix

Gerry Cleary

7/30/2019

0.3

Slight wording edits – (a) Section 5 “workers” changed to“employees” for consistency with rest of document (b)Section 10 “personal representative” changed to colleague

Gerry Cleary

01/12/2019

0.3

No Changes

Gerry Cleary

12/16/2019

0.3

Reviewed and Approved

02/18/2020

0.3

Scope adjusted to include reference to freelancers andcontractors

12/14/2020

0.3

Reviewed and Approved

11/29/20210.3

Replaced ‘company’ with ‘group’

12/2021

0.3

Reviewed and Approved

11/2023

0.4

Minor changes and design update

13/11/2023

0.4

Reviewed and Approved

Audit Committee
Gerry Cleary
Audit Committee
Gerry Cleary
ESG
Ekaterina Ustina
Risk & Compliance
Committee

CONFIDENTIAL AND PROPRIETARY - Proprietary notes apply. Printed documents are subject to change. Verify correct revision before use.
PROPRIETARY NOTE: This document contains information proprietary to Keywords Int’l. Any disclosure or use is expressly prohibited, except upon explicit written permission.

Document Title

Document No.

Version

GLB-HR-23-11-INT
Grievance Policy & Procedure

0.4

Last Revision Date

Nov. 13, 23

Page 2 of 5

Table of Contents
1.

AIMS ........................................................................................................................ Error! Bookmark not defined.

2.

SCOPE .................................................................................................................................................................... 33.

REVIEW ................................................................................................................................................................... 3

4.

FEEDBACK .............................................................................................................................................................. 3

5.

INTRODUCTION ..................................................................................................................................................... 3

6.

INFORMAL PROCEDURE ....................................................................................................................................... 3

7.

FORMAL PROCEDURE........................................................................................................................................... 38.

APPEAL ................................................................................................................................................................... 4

9.

CONFIDENTIALITY ................................................................................................................................................. 4

10. RIGHT TO BE ACCOMPANIED ............................................................................................................................... 4
11. RECORDS ............................................................................................................................................................... 4
12. OTHER POLICIES ................................................................................................................................................... 4
13. RESPONSIBILITIES ................................................................................................................................................. 4

Appendix – India Specific Instructions ........................................................................................................................................ 5

CONFIDENTIAL AND PROPRIETARY - Proprietary notes apply. Printed documents are subject to change. Verify correct revision before use.
PROPRIETARY NOTE: This document contains information proprietary to Keywords Int’l. Any disclosure or use is expressly prohibited, except upon explicit written permission.

Document Title

Document No.

Version

GLB-HR-23-11-INT
Grievance Policy & Procedure

0.4

Last Revision Date

Nov. 13, 23

Page 3 of 5

1. PURPOSE
This policy is designed to ensure that, where the group or the employee is not fulfilling their workplace obligations
to each other, there is a defined impartial and consistent process through which such issues can be resolved.

2. SCOPE
The Grievance Policy applies to all employees of Keywords Studios (the “Group”) and is for the information of those
who provide freelance or contractual services to Keywords.

3. REVIEW
The management team is responsible for the ongoing review of this document. This will be carried out annually oras and when organisational changes impact the way the group works. An amendment record will be maintained todocument the changes made in each new issue.

4. FEEDBACKFeedback regarding this document should be directed to any one of the department managers.

5. INTRODUCTION
In any group, employees may have problems or concerns about their work, working conditions or working
relationships. It is in everyone’s best interest to ensure that these problems and concerns are addressed in goodtime and are not exacerbated over time.
The Grievance Procedure provides a mechanism for dealing with problems and concerns as quickly and as fairly
as possible and at every level throughout the Group.

6. INFORMAL PROCEDURE
The first stage of resolving any grievance is usually to seek to resolve it in an informal manner, either with yourmanager or the individual with whom the grievance relates. You may seek advice from colleagues or the HRDepartment and they may become involved in seeking to resolve your grievance in an informal manner.
If the grievance is not resolved to your satisfaction at an informal level or if you would prefer to make a formal
application in relation to your grievance, you should move to the next stage of this procedure.

7. FORMAL PROCEDURE
If you have a grievance relating to your employment which has not been resolved to your satisfaction at an
informal level or, in relation to which, you would prefer to make a formal application, you will need to submit yourgrievance in writing, setting out the reasons for your grievance, either to your line manager or the HR Manager as
appropriate.
The document containing the written details of your grievance should be marked “Formal Grievance” so that therecipient is in no doubt that you are following this procedure.
Once your grievance has been submitted the following principles will apply:
•••
•
•
•

Depending on the seriousness, the grievance will be investigated either by the person to which the grievancehas been addressed or another appropriate member of the management team.
You will be notified of a date and time for a meeting at which you have the right to be accompanied by acolleague or personal representative of your choice so that your grievance can be heard.
The investigating manager may ask you further questions or request further evidence at this meeting.
The investigating manager may need to make a wider investigation, as appropriate, to establish and/or verify
the facts.
Every effort will be made to give a response in a reasonable time frame. However, depending on thecomplexity of the case, the investigating manager will update you as appropriate.
Once a decision has been reached, you are entitled to appeal the decision, stating the reasons for yourdisagreement with the outcome.

CONFIDENTIAL AND PROPRIETARY - Proprietary notes apply. Printed documents are subject to change. Verify correct revision before use.
PROPRIETARY NOTE: This document contains information proprietary to Keywords Int’l. Any disclosure or use is expressly prohibited, except upon explicit written permission.

Document Title

Document No.

VersionGLB-HR-23-11-INT
Grievance Policy & Procedure

Last Revision Date

Nov. 13, 23

8.

0.4
Page 4 of 5

APPEAL
Should you wish to appeal the decision, this should be submitted in writing to a person of appropriate seniority,(usually one level above the person who has heard the grievance), setting out the reasons for the appeal. Theappeal should be submitted within 5 working days of receipt of the grievance decision unless a nationalemployment contract clearly states a conflicting timeline. In this case, the national employment contract will takeprecedence.
The person holding the appeal will review the evidence against the grounds you have raised for appeal and makesuch enquiries as may seem appropriate to them. You will be given an opportunity to state your case. Where new
evidence comes to light it may be appropriate to adjourn the appeal hearing for further investigation.
The decision of the person holding the appeal will be final.

9.

CONFIDENTIALITY
The group will aim to keep the facts and circumstances of your grievance confidential. However, that may notalways be fully possible where, for example, a large number of your colleagues have to be interviewed in theprocess of resolving your grievance.

10. RIGHT TO BE ACCOMPANIED
You have the right to be accompanied to grievance hearings by a colleague. That person may attend the hearing
and ask questions, but may not answer questions on your behalf. Your choice of person to accompany you must
be reasonable. If your request is not reasonable, such as the person having a conflict of interest, you may be
asked to choose an alternative person. If the person you have chosen to accompany you is not available on thedate proposed for the disciplinary hearing, you may offer a reasonable alternative date.
The person conducting the grievance hearing and the person conducting any appeal will generally be
accompanied by a colleague who will take written notes of the proceedings.

11. EMPLOYEES RIGHTS
In the case of reporting a grievance employees remain protected by the Keywords Code of Conduct, equal
opportunities commitment, non-discrimination and anti-harassment processes. This policy should not beinterpreted to interfere with employees’ rights under national laws or local laws. Importantly, employees should
not face adverse circumstances or retaliation for submission of a grievance from the reported party; theinvestigator(s); or other colleagues. Nor should employees face consequences different than those that would be
met by colleagues of other characteristics.

12. RECORDS
The group will usually retain copies of documents detailing the nature of any grievance, any action taken alongwith explanation, whether an appeal was lodged and its outcome, and any subsequent developments.

13. OTHER POLICIESThis policy can be used by any employee who wishes to raise a grievance. However, there are certain sorts ofgrievance which are better dealt with under other policies and if appropriate, you may be directed towards
another procedure. In all situations, if a national policy is already in place, the guidelines of that policy are to beadhered to.

14. RESPONSIBILITIES
Keywords Senior Management is responsible for implementing, maintaining and interpreting this document.

End of document.

CONFIDENTIAL AND PROPRIETARY - Proprietary notes apply. Printed documents are subject to change. Verify correct revision before use.
PROPRIETARY NOTE: This document contains information proprietary to Keywords Int’l. Any disclosure or use is expressly prohibited, except upon explicit written permission.

Document Title

Document No.

Version

GLB-HR-23-11-INT
Grievance Policy & Procedure

0.4

Last Revision Date

Nov. 13, 23

Page 5 of 5

Appendix – India Specific Instructions
INDIA STUDIO SPECIFIC CLAUSES
1.

Section #7 of the policy document, the Formal Procedure, states “If you have a grievance relating to youremployment which has not been resolved to your satisfaction at an informal level or, in relation to which,
you would prefer to make a formal application, you will need to submit your grievance in writing, settingout the reasons for your grievance, either to your line manager or the HR Manager as appropriate.”

2. Grievance submission at an India studio should be as per the below given matrix. However, the remainderof the process as mentioned in section #7 will be followed.
3. Section #10 of the policy refers to the “Right to be accompanied”. This is not typical practice during an
Indian Grievance Procedure and is not applicable to India Studios. HR will be present at all meetings at alllevels to record the proceedings.

Role

Area ofGrievanceFirst LevelArtist

ProjectGeneral

Project Lead
Regional Art Director Studio Art Director
India Production HeadRegional Art Director Studio Art Director / India Production Head India CEO
Studio HeadQCProjectGeneral

Project Lead
QC LeadProject Coordinator /Project Manager

Work Related / Sr. Project Manager / Lead Project Manager/ India Production Head India CEOGeneral
Project Manager
Studio Head(Level 2)
Project/ General Project Lead
Project Manager
QA Manager
Head HR / CEOTesters (Babel)

Other Departments
Work Related / Manager
including Localisation General

Second Level

QC LeadStudio Art Director /Studio Head

Department Head

Third Level

Fourth Level

Studio Art Director
India Production Head
India Production Head India CEO

India CEO / India
Production Head (asapplicable)

Note: At all levels it is mandatory to keep HR in loop.

CONFIDENTIAL AND PROPRIETARY - Proprietary notes apply. Printed documents are subject to change. Verify correct revision before use.
PROPRIETARY NOTE: This document contains information proprietary to Keywords Int’l. Any disclosure or use is expressly prohibited, except upon explicit written permission.