Policy: Social Media Policy
Ref. # HRD/PP/008/010/2023
Prepared by: HR Department
Policy Applicability All MTMs
Reviewed / Approved by: Corporate Head/Group CHRO
Date: 18-10-2023
1. Basic Principles
(a) The purpose of this “Social Media Policy” is to ensure that any Online Activity (hereinafter defined)
undertaken by MTMs is done responsibly with no detriment to the Company or themselves.
(b) MTMs should not undertake any Online Activity that could embarrass the Company or could be
detrimental to the interests of the Company, its directors, officers, or other employees compromise their
ability to do their job. The term “Online Activity” includes writing, creating, sharing, posting, or
propagating anything on social media (including chat windows, messengers, SMS, WhatsApp groups, or
other social media platforms / applications like LinkedIn, Instagram, Facebook etc) or other Online
Platform where any Online Activity is carried out shall be referred to as an “Online Platform.”
(c) MTMs should assume that their professional and personal lives will merge online regardless of the care
taken in separating them.
(d) MTMs should assume, regardless of adopting any privacy tools, that anything written, exchanged, or
received on a social media site is public.
(e) The general duties and obligations of MTMs under the Policies, without limitation, in relation to the
protection of Confidential Information and Intellectual Property, will be equally applicable to MTMs in
relation to any Online Activity undertaken by them.
2. Do’s for MTMs
(a) MTMs may use social media sites and undertake Online Activity only to the extent that the ability to do
their job is not compromised (and in any case not during working hours.)
(b) Unless authorized to represent the Company on Online Platforms, MTMs must expressly state that any
views expressed are their own when commenting about the business of the Company on any Online
Platform.
This policy document belongs to Malabar Group HR Department for intended use only
(c) MTMs should be open-minded and tolerant when interacting on Online Platforms. The Company will not
condone any form of discrimination on account of sex, race, color, caste, religion, ethnicity, sexual
orientation, or any other form of discrimination, whether barred by law or otherwise.
(d) MTMs should adhere to the rights and obligations set out under this “Social Media Policy” even when
undertaking Online Activity on personal devices such as smartphones and tablets.
(e) If MTMs have any doubts or require any clarifications about this “Social Media Policy”, they should
approach their reporting manager with their queries.
3. Don’ts for MTMs
(a) MTMs should not reveal any Confidential Information, including that relating to any Intellectual Property,
on any Online Platform.
(b) MTMs should not misrepresent their designation or position within the Company during any Online
Activity.
(c) MTMs should not use the Company’s name, trademark, or logos as part of any Online Activity unless
expressly authorized to do so by the Company.
(d) Unless specifically authorized on this behalf, MTMs should not undertake Online Activity in relation to
any Company Forum (hereinafter defined).
(e) MTMs should not, during any Online Activity, reference clients, customers, vendors, directors, managers,
partners, shareholders, colleagues, officers or other MTMs or ex-employees without their consent and
approval.
(f) MTMs should not make any negative remarks or disparaging statements about or against the Company,
colleagues, ex-employees, officers, directors, shareholders, clients, customers, managers or partners or
consultants (“Non-disparagement Obligation”).
4. Post-separation Obligations
(a) Post the separation from employment, the obligation of MTMs, whether under this “Social Media Policy”
or generally under the Policies, to protect the Confidential Information of the Company and rights relating
to Intellectual Property, shall continue, while undertaking Online Activity and otherwise.
(b) During the tenure of employment and thereafter, the MTM agrees not to undertake any Online Activity
which is intended or would reasonably be expected, to harm the Company or which would reasonably be
expected to lead to unwanted or unfavourable publicity to the Company.
(c) The MTM shall continue to be bound by the Non-disparagement Obligation, as stated above, post the
cessation of employment.
This policy document belongs to Malabar Group HR Department for intended use only
5. Consequences of Breach of this Policy
(a) Any breach of this “Social Media Policy” will be treated as Misconduct under this Handbook. Apart from
taking action for Misconduct, depending on the nature of the breach, the Company also retains the right
to pursue any other legal course of action, including but not limited to approaching the courts or law
enforcement authorities.
(b) As in this case of any other Misconduct, MTMs will be subject to an Enquiry for any breach of this “Social
Media Policy”, and penalty for the same may range from warning and fine up to termination from
employment.
(c) The Company may initiate appropriate legal proceedings against MTMs who breach this “Social Media
Policy,” whether during or post the tenure of employment. Compensation in money shall not be deemed
an adequate remedy in the event of the breach of the terms hereof by MTMs, and the Company may, at
its discretion, choose to seek such other legal remedies as are recognized under law. Without prejudice
to any other rights, which the Company may have against the MTMs, the Company shall be entitled to
enforce specific performance of the terms of this “Social Media Policy” and to obtain injunctive relief
against the MTMs, if deemed appropriate.
6. Rights and Obligations of the Company
(a) The Company shall, if necessary, conduct training or workshops, explaining the scope and purpose of the
“Social Media Policy” to bring awareness among MTMs.
(b) If any content published by an MTM on an Online Platform is, in the sole discretion of the Company,
determined to be objectionable, the Company may seek removal or amendment of such content, with
immediate effect, and the MTM is obligated to comply with any instructions in this regard.
(c) The Company may, on its own behalf, set up profiles or accounts on Online Platforms (“Company
Forum”). MTMs may only use the Company Forum if specifically authorized to do so on this behalf in
writing. Further, MTMs should generally refrain from posting anything on a Company Forum without prior
written approval.
(d) The Company will provide internal mechanisms for addressing MTM grievances and whistle-blowing.
MTMs are strongly urged to avail of these internal mechanisms in case of any issues or grievances, instead
of resorting to Online Activity.
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This policy document belongs to Malabar Group HR Department for intended use only
