Latest Blogs from SBS and Company LLP

    The last decade has seen unprecedented growth in India’s financial services sector. It employs over 3 million people, constitutes about 5% of the GDP and has an estimated market capitalization of over US$ 200 billion. As India experiences continued economic growth, the financial sector could generate about 10-11 million jobs and a GDP contribution of US$ 350 to US$ 400 billion by 20201 . With a sustained growth and rapid development in technology and infrastructure, an increasing share of financial services would get centralized. McKinsey & Company’s market assessment report estimates potential of about 6 million centralized jobs across multiple service roles.

     

    Several developed countries have successfully established high-tech financial hubs, which over time have catered as international financial services centers. These centers provide suitable regulatory regimes and create a business environment to promote talent and increase capital flow. As they develop they create significant economic value for their respective domestic economies, e.g. financial services in London and New York account for 10% of the GDP and about 5% of jobs. Emerging financial services centers like Singapore and Hong Kong have achieved similar levels of concentration of economic activity over short periods of time.

     

    With the above background the author has made an attempt to analyze the present status of IFSC Regulations and how India is positioned itself to capture the Global opportunities.

     

    What is IFSC?

     

    An international financial services centreprimarily caters to customers outside the jurisdiction of domestic economy, dealing with flows of finance, financial products and services across borders

     

    Section 2(q) of Special Economic Zones Act, 2005 has defined “International Financial Services Centre” means an International Financial Services Centre which has been approved by the Central Government under sub-section (1) of section 18

     

    The provisions of Section 18 of the SEZ Act, 2005 is been reproduced for ready reference

     

    Setting up of International Financial Services Centre

     

    1. (1) The Central Government may approve the setting up of an International Financial Services Centre in a Special Economic Zone and prescribe the requirements for setting up and operation of such Centre :

     

    Provided that the Central Government shall approve only one International Financial Services Centre in a Special Economic Zone.

     

    The Central Government may, subject to such guidelines as may be framed by the Reserve Bank, the Securities and Exchange Board of India, the Insurance Regulatory and Development Authority and such other concerned authorities, as it deems fit, prescribe the requirements for setting up and the terms and conditions of the operation of units in an International Financial Services Centre.

    Present Regulatory Architecture

     

    It can be observed from the above diagram that the IFSC related activities are governed by several Regulators based on the nature of activities being undertaken.

     

    Reserve Bank of India (RBI) regulates the IFSC Banking Units (IBU) as a Banking Regulator and also regulates the Foreign Exchange control Regulations.

     

    Insurance Regulatory and Development Authority of India (IRDAI) regulates the activities of Insurance companies in IFSC

     

    Securities and Exchange Board of India (SEBI) regulates the operations of intermediaries dealing in Securities and Commodities and their derivatives

     

    Pension Fund Regulatory and Development Authority (PFRDA) regulates the operations of entities dealing in such funds and having operations in IFSC

     

    Subsequent to the below regulatory developments India has set up first IFSC in Gujarat International Finance Tec-City Company Limited (GIFT City), Gandhi Nagar, Gujarat, India. For more details of GIFT city, the reader may refer to the website http://giftgujarat.in

     

    What are the services an IFSC can provide?

     

    ?Fund-raising services for individuals, corporations and governments

    ?Assetmanagement and global portfolio diversification undertaken by pension funds, insurance companies and mutual funds

    ?Wealthmanagement

     

    ?Globaltax management and cross-border tax liability optimization, which provides a business opportunity for financial intermediaries, accountants and law firms.

    ?Globaland regional corporate treasury management operations that involve fund-raising, liquidity investment and management and asset-liability matching

    ?Riskmanagement operations such as insurance and reinsurance ?Mergerand acquisition activities among trans-national corporations

     

    What does an IFSC require?

     

    IFSCs such as Dubai International Financial Centre and Shanghai International Financial Centre, which are located within SEZs, have six key building blocks:

     

    ?Rationallegal regulatory framework

    ?Sustainable local economy

    ?Stablepolitical environment

    ?Developed infrastructure

    ?Strategiclocation

    ?Goodquality of life

     

    Keeping the above issue in sight, the Indian Government has made many changes and is making efforts to create sustainable and conducive environment to attract the global players to India.

    Brief of Regulatory Developments in India

     

    01-03-2015       Press Release issued by PIB for setting up first IFSC in Gandhi Nagar, Gujarat

     

    02-03-2015       RBI has issued FEMA (IFSC) Regulations, 2015

     

    27-03-2015       SEBI has issued SEBI (IFSC) Guidelines, 2015

     

    27-03-2015     Ministry of Finance (Department of Financial Services) has issued notification for giving many relaxations to the Insurance Companies from various provisions of Insurance Act, 1938

     

    27-03-2015     Ministry of Finance (Department of Financial Services) has issued notification IRDAI (Regulation of Insurance Business in Special Economic Zone) Rules, 2015 for permitting insurance companies to set up operations in IFSC

     

    01-04-2015     RBI has framed schemeto all Scheduled Commercial banks (including foreign banks)for setting up IFSC Banking Units (IBU)

     

    06-04-2015       IRDAI has issued guidelines titled IRDAI (IFSC) Guidelines, 2015

     

    08-04-2015     Ministry of Commerce and Industry has issued notification permitting setting up of IFSC under SEZ Act, 2005 and rules made thereunder and also notified suitable application form for setting up such IFSC units

     

    17-03-2016     SEBI has amended the guidelines to include the Commodity Derivatives for IFSC operations

     

    28-11-2016     SEBI has issued guidelines to Stock Exchanges and Clearing Corporation to set up their operations in IFSC

     

    10-04-2017     RBI has issued Directions to the IBUs to carry on the clearing operations in IFSC without forming separate entity and also permitted to open SNRRA for local expenses

     

    13-04-2017     SEBI has further amended the guidelines to include the Derivatives on Equity Shares for IFSC operations

     

    27-04-2017       SEBI has further amended the guidelines to permit IBUs to carry on TCM and PCM activities for Stock exchanges/ Clearing Corporation in IFSC as well as domestic activities

    FEMA Regulations:

     

    RBI,inter alia, has framed around 27 Regulations under FEMA, concerning various activities between Residents in India and Non Residents.

     

    Foreign Exchange Management (International Financial Service Centre) Regulations, 2015 (“FEMA Regulations”) deals with the permissible transactions in IFSC as per Foreign Exchange Management Act, 1999

     

    As per Regulation 3 of FEMA Regulations, any financial institution or branch of a financial institution set up in the IFSC and permitted/recognized as such by the Government of India or a Regulatory Authority shall be treated as a person resident outside India and accordingly any transaction taken place between such IFSC entity and Residents in India needs to comply with other regulations framed under FEMA, 1999

     

    As per Regulation 4 of FEMA Regulations, a financial institution or branch of a financial institution shall conduct such business in such foreign currency and with such persons, whether resident or otherwise, as the concerned Regulatory Authority may determine

     

    As per Regulation 5 of FEMA Regulations read with Section 1(3) of FEMA, 1999 all other regulations framed under FEMA are not applicable to the IFSC in case the activities are carried with in the IFSC and subject to these FEMA Regulations.

     

    Commercial banks are allowed to open IBUs within IFSC, which are deemed as overseas branches. Such IBUs can trade in foreign currencies in overseas markets and also with Indian banks, raise funds in foreign currency as deposits and borrowings from non-resident sources and provide loans and liability products for clients.

     

    SEBI Regulations

     

    As per SEBI (IFSC) Guidelines, 2015 any intermediary located in IFSC viz., a stock broker, a merchant banker, a banker to an issue, a trustee of trust deed, a registrars to an issue, a share transfer agent, an underwriter, an investment adviser, a portfolio manager, a depositary participant, a custodian of securities, a foreign portfolio investor, a credit rating agency, or any other intermediary or any person associated with the securities market, as may be specified by the Board from time to time, can deal in securities, commodities and their derivatives in a Foreign Jurisdiction [as defined in clause 2(f)]

     

    All the entities willing to set up operations in IFSC shall be first registered with SEBI as an intermediary as per respective regulations framed by SEBI and shall comply with all the applicable regulations including IFSC regulations.

     

    In case of Stock Exchanges, Clearing Corporations and Depositories, willing to carry on IFSC activities shall form separate Subsidiary Companies (holding at least 51% of paid-up Equity ‘share capital) and the balance shares can be held by any other stock exchange, clearing corporation or Depository, (whether Indian or foreign jurisdiction),as the case may be.

    The stock exchange shall have minimum networth of Rs. 25 Crores initially and shall enhance it to Rs. 100 Crores over a period of 3 years from the date of approval. Similarly Clearing Corporation shall have initial networth of Rs. 50 Crores and to be enhanced to Rs. 300 Crores, over a period of 3 years. Also the Depository shall have initial networth of Rs. 25 Crores and shall enhance it to Rs. 100 Crores over a period of 3 years.

     

    Many provisions of SEBI related to depositories, stock exchanges, clearing corporations operating in IFSC are not applicable as per exemptions given under Rule 6 of SEBI Guidelines

     

    Pursuant to the IFSC Guidelines, depositories, stock exchanges, clearing corporations operating in IFSC shall adopt the broader principles of governance prescribed by International Organization of Securities Commissions (IOSCO) and principles for Financial Market Infrastructures (FMI) and such other governance norms as may be specified by the SEBI, from time to time

     

    As per clause7, the stock exchanges operating in IFSC are permitted to deal in following types of securities and products in such securities in any currency other than Indian rupee, with a specified trading lot size on their trading platform subject to prior approval of the SEBI:

     

    • Equity shares of a company incorporated outside India;
    • Depository receipt(s);
    • Debt securities issued by eligible issuers;
    • Currency and interest rate derivatives;
    • Index based derivatives;
    • Such other securities as may be specified by the Board.

     

    SEBI has prescribed Commodity Derivatives as “other securities” under the aforesaid clause. Also SEBI has prescribed Derivatives on equity shares of a company incorporated in India, by Foreign Portfolio Investors as “other securities” under the aforesaid clause

     

    Further, it also provides that SEBI registered Foreign Portfolio Investors (FPIs), operating in IFSC, and eligible entities, which are incorporated and operating in IFSC, shall be eligible to trade in such derivatives on equity shares.

     

    Market Wide Position Limit (MWPL) for such derivatives on equity shares shall be as prescribed by SEBI from time to time.

     

    Earlier this year, the SEBI simplified the IFSC onboarding process for FPIs and eligible foreign investors as under:

     

    ?Noadditional documentation and/or prior approval required for SEBI registered FPIs ?Atradingmember may rely on the due diligence already carried out by :

     

    -a SEBI registered intermediary for FPIs

    - a bank operating in IFSC for eligible foreign investors

    As per latest amendment dated 27-04-2017, SEBI has permitted IBUs to carry on the operations both in Domestic market and Foreign Jurisdiction as Single entity, thereby paving way for more IBUs to enter into the IFSC operations. Also the IBUs are permitted to open Special Non-Resident Rupee Account in India to meet the administrative expenses in INR

     

    Conclusion:

     

    While many reforms in the area of IFSC have been brought by India, there are certain things still to be done. Some of these issues have been addressed in speech titled “Macro and Micro Drivers of Business Potential of IFSCs in India”, by Dr. Urjit R. Patel, Governor of RBI – January 11, 20172 – at Gandhinagar, Gujarat, regarding other steps to be taken, inter alia, micro ecosystem in IFSC, a modern complementary legal infrastructure that is sufficiently supportive of the swift resolution of conflicts and disputes arising from the settlement/enforcement of complex international financial contracts. The contract should be of international standard and enforceable in the court of law and preferably similar to ISDA documentation

     

    In addition he has opined to have a unified financial regulatory framework providing for a single regulator for IFSC could contribute to better regulation and supervision of the financial entities in the IFSC. While individual regulators can supervise the entities initially when the size of the business is small, a unified regulator would be necessary to pay undivided attention to the IFSC. Work on the design of such a framework should begin soon so as to be able to implement this in time.

     

    Once India implements many of the above reforms and pave the way for effective economic and regulatory reforms, India is poised to play key role in the global economic activity and also provide lot of support for the Economic Development in India and employment generation to the tune of 1 Million 3 Jobs in India.

    Tags:

    Country By Country Reporting – Implementation Guidance:

     

    Currently, CBCR compliances has become a matter of concern for all multinational enterprises (MNE). The Organization for Economic Cooperation and Development (OECD) as part of the BEPS project has been issuing guidance to the action points specified by it. Recently on 6 April 2017, the OECD released an updated version of the Guidance on the Implementation of Country-by-Country Reporting (‘the Guidance’) which has addressed five new issues:

     

    • The definition of terms “related party revenues” & “revenue” used in the CbCR;
    • The definition of total consolidated group revenue;
    • The accounting principles for determining the existence of and membership in a group;
    • Treatment of major shareholding; and
    • Transitional filing options for MNE groups.

     

    1. Definition of related party and revenues

     

    The Guidance clarifies that the revenue referred to in Table 1 of CbCR shall include extraordinary income and gains from investment activities. While this may not necessarily reflect just the operating results of the constituent entities, it would at least do away with the ambiguity on what constitutes ‘extraordinary income’ and varying yardsticks that MNE groups would apply.

     

    The Guidance further mentions that “related parties” in Table 1 of CbCR, which are defined as “Associated Enterprises” in the Action 13 report should be interpreted as ‘Constituent Entities’ listed in Table 2 of the CbCR. In the Indian context, this is defined in section 286 of the Income Tax Act 1961 (‘the Act’) largely aligned to the OECD definition in the Action 13 report which includes permanent establishments and does not give any leeway in terms of materiality of a company in terms of the group size.

     

    1. Definition of the total consolidated group revenue

     

    The Guidance clarifies that for determining the total consolidated group revenue (to see if the threshold of EUR 750 million is breached by a MNE group), all of the revenue reflected in the consolidated financial statements should be used. Further, in line with the definition of revenues for Table 1, the Guidance also provides that the jurisdictions are allowed to require inclusion of extraordinary income and gains from investment activities in the total consolidated group revenue if such inclusion is called for under the applicable accounting rules.

     

    The applicable accounting standard therefore could either push companies into the realms of CbCR or save it from having to comply with CbCR filing.

    Country By Country Reporting – Implementation Guidance:

     

    Currently, CBCR compliances has become a matter of concern for all multinational enterprises (MNE). The Organization for Economic Cooperation and Development (OECD) as part of the BEPS project has been issuing guidance to the action points specified by it. Recently on 6 April 2017, the OECD released an updated version of the Guidance on the Implementation of Country-by-Country Reporting (‘the Guidance’) which has addressed five new issues:

     

    • The definition of terms “related party revenues” & “revenue” used in the CbCR;
    • The definition of total consolidated group revenue;
    • The accounting principles for determining the existence of and membership in a group;
    • Treatment of major shareholding; and
    • Transitional filing options for MNE groups.

     

    1. Definition of related party and revenues

     

    The Guidance clarifies that the revenue referred to in Table 1 of CbCR shall include extraordinary income and gains from investment activities. While this may not necessarily reflect just the operating results of the constituent entities, it would at least do away with the ambiguity on what constitutes ‘extraordinary income’ and varying yardsticks that MNE groups would apply.

     

    The Guidance further mentions that “related parties” in Table 1 of CbCR, which are defined as “Associated Enterprises” in the Action 13 report should be interpreted as ‘Constituent Entities’ listed in Table 2 of the CbCR. In the Indian context, this is defined in section 286 of the Income Tax Act 1961 (‘the Act’) largely aligned to the OECD definition in the Action 13 report which includes permanent establishments and does not give any leeway in terms of materiality of a company in terms of the group size.

     

    1. Definition of the total consolidated group revenue

     

    The Guidance clarifies that for determining the total consolidated group revenue (to see if the threshold of EUR 750 million is breached by a MNE group), all of the revenue reflected in the consolidated financial statements should be used. Further, in line with the definition of revenues for Table 1, the Guidance also provides that the jurisdictions are allowed to require inclusion of extraordinary income and gains from investment activities in the total consolidated group revenue if such inclusion is called for under the applicable accounting rules.

     

    The applicable accounting standard therefore could either push companies into the realms of CbCR or save it from having to comply with CbCR filing.

     

    The Guidance also specifically recognizes that in the case of financial entities, gross amounts from transactions may not be recorded in their financial statements, the item(s) considered similar to revenue under the applicable rules should be used in the context of financial activities. The Guidance captures a specific example of interest rate swap wherein revenue is reported on a net basis and the same is what would be used to determine the total consolidated group revenue.

     

            3. Accounting principles/ standards for determining the existence of and membership of group

    For the purpose of determining the constituent entities of a group, the Guidance recommends companies having their shares listed in a public stock exchange to follow the consolidation rules in the accounting standards already used by the group. For other companies, the OECD has provided an option to either use local GAAP of the jurisdiction of the ultimate parent entity or IFRS unless the jurisdiction of the ultimate parent entity mandates the use of a particular accounting standard.

     

    The choice of a particular accounting standard becomes important in terms of the following;

     

    • Which entity/ group would an entity be considered as part of for determining the group revenue.

     

    • Whether an investment fund company would be required to consolidate its financial statements.

     

    1. Treatment of major shareholding

     

    The Guidance leaves it to the prevailing accounting standard to determine how much of the revenue of the entity is to be included in the groups consolidated financials where minority interest exists. A pro-rata basis or 100 % of the entities revenues could be used for the revenue threshold reporting revenues in the relevant Tables.

     

    1. Transitional filing options for MNEs

     

    OECD recommends that countries implement CbCR for periods commencing January 2016 for which the last day of filing the CbCR is 12 months from the end of the fiscal year (‘Applicable Deadline’). For countries that are not aligned with these dates, transitional issue arises. To overcome this, jurisdictions may accommodate voluntary filing of CbCR in their jurisdiction of tax residence (‘parent surrogate filing’). The Guidance also lists out countries which have already enabled the parent surrogate filing for fiscal periods commencing on or after 1 January 2016 in their jurisdictions which inter alia include countries such as China, United States of America (‘US’) and Japan.

     

    The Guidance also provides that, inter alia, where the CbCR filing has been undertaken by the ultimate parent entity (‘UPE’) or surrogate parent entity (‘SPE’) resident in a particular jurisdiction before the Applicable Deadline, and there exists a qualifying competent authority agreement between UPE/ SPE tax jurisdiction and that of the constituent entities’ tax jurisdiction, then there ought to be no filing obligations in the constituent entities’ jurisdiction.

     

    An issue that Indian MNE Groups may have to immediately grapple with is what happens with respect to constituent entities resident of tax jurisdictions which are yet to sign the MCAA but have CbCR filing obligations which fall before the Indian filing deadline of 30 November 2017 (one such example could be China).

     

    Updated -UN TP Manual:

    On 7 April, 2017, United Nations (UN) has published updated TP Manual that contains new chapters on intra-group services, cost contribution arrangements and on the treatment of intangibles; the updated UN TP manual incorporates developments relating to Base Erosion and Profit Shifting (BEPS) project including revised guidance on documentation and business restructuring. The updated version has been divided into 4 parts for better clarity –

     

    1. Transfer pricing in a global environment,
    2. Substantive guidance on arm’s length principle,
    3. Practical implementation of TP regime and
    4. Country practices;

     

    The following are the new chapters that are incorporated as part of the updated UN TP Manual:

     

    Intra-group services

     

    The chapter is based on the rationale that if specific group members do not need the activity and would not be willing to pay for it if they were independent, the activity cannot justify a payment, and further, any incidental benefit gained solely by being a member of an MNE group, without any specific services provided or performed, should be ignored.

     

    The concept of benefit test is explained under various situation such as services are provided to meet specific need of AE and when centralized services are provided along with examples. The Chapter states the 4 situations where charge is not justified as benefit test is not met viz. shareholder activities, duplication of services, benefit arising only out of passive association with MNE group and incidental benefit giving appropriate examples.

     

    The chapter also elaborates upon various method to determine arm's length price, direct and indirect charge mechanism and allocation keys. The Chapter provides for 2 safe harbour mechanisms for low value services and minor intra-group expenses.

     

    Cost contribution arrangements

     

    The Chapter covers issues such as value of CCA contributions, treatment of government subsidies, predicting expected benefits, CCA entry, withdrawal and termination and CCA guidelines and

     

    Tags:

    In Industrial and Commercial Organisations, it is the normal practice that the new employees are taken on probation. The probationary period may range between six months to two years depending on the nature of the role and responsibilities. During the probationary period a new employee performance and behaviour is required to be monitored and provide close supervision and coaching, guidance and training, either to learn a new job or to turn around a performance problem. The period is also required to be utilised to make the new employee to understand and integrate with the culture of the organisation besides systems and processes of working. The intent and object of such probationary period is rarely utilised by the organisations.

     

    The other purpose of probationary period is to suspend or modify the usual employment rules for an employee and to understand and assess his or her on the job competencies, potential, behaviour patterns and commitment to the organisation and its objectives.

     

    The implied promise or threat of a probationary period is that the employee will have to utilise the opportunity and perform to best of his abilities and if the employee fails to do so, he may not be considered for permanent employment and lose his employment at the end of probation or during the period of the probation.

     

    To achieve the real objectives of the probationary period organisations may practice the below mentioned policies.

     

    • Notify the employee the probationary period, the intent and consequences.
    • Conduct periodic reviews with the employee to provide feedback and counselling.

     

    • If the employee is having performance issues, detailed guidance may be provided on how the employee can improve—and offer training, if necessary.

     

    • Assign a knowledgeable and experienced mentor to advise the employee.
    • Treat the employee fairly and consistently.

     

    • If an employee can’t do the job or improve performance, clearly document everything ie. employee’s performance, your efforts to coach and manage, training provided and so on.

     

    The model standing orders provided in the Industrial Employment Standing Order Act has defined probationer as a workman who is provisionally employed to fill a permanent vacancy in a post and has not completed three months service therein. If a permanent employee is employed as a probationer in a new post he may, at any time during the probationary period of three months, be reverted to his previous permanent post.

     

    Model standing orders are the guiding principles to the employer for finalisation of its own standing orders and certification of the same. When once the company standing orders are certified, the probationary period mentioned therein will be applicable. The three months mentioned therein is only indicative and not necessary applicable to all organisations.

    The employer normally incorporates the period of probation and terms of extension of the same in the appointment order. If there is any conflict between the certified standing orders and the appointment order, the provisions contained in the certified standing orders shall prevail.

     

    Most of the employees and also some of the employers believe that if no action is taken at the end of the probationary period and the employee is continued in the employment, it is deemed confirmation. It is not true. It will become deemed confirmation only if the rules of the company or the appointment order or the standing orders specifically incorporates such provision. The Constitution Bench in the matter of Sukhbans Singh V. State of Punjab and also in the matter of G S Ramaswamy and Ors v. Inspector-General of Police, Mysore has opined that a probationer cannot, after the expiry of the probationary period, automatically acquire the status of a permanent member of the service, unless of course, the rules under which he is appointed expressly provide for such a result.

     

    Therefore even though a probationer may have continued to act in the post to which he is on probation for more than the initial period of probation, he cannot become a permanent servant merely because of efflux of time, unless the Rules of service which govern him specifically lay down that the probationer will; be automatically confirmed after the initial period of probation is over.

     

    If provided in the appointment order, the services of the probationer can be terminated at the end of the probationary period or during the course of the probationary period without conducting an enquiry in accordance with the terms of employment. The Honble Punjab & Haryana HC in the matter of Jitender Kumar VS. P O, Industrial Tribunal-cum-Labour Court, Gurgaon [2014 LLR 985] confirmed this view and the facts of the matter are as under:

     

    The workman was appointed initially on 12.01.2001, on probation for a period of six months after two years of training. As per the appointment order the probationary period is liable to be extended at the sole discretion of the Management and workman is deemed to be on probation unless confirmed in writing. In accordance with the terms of appointment order the probationary period was extended for 3 months on 12.07.2001 till 11.10.2001, after advising him to be more careful in future by considering his appraisal report and asked him to improve his work and conduct. On 09.10.2001 that is just before completion of the extended probationary period the Management discharged the workman by holding that his work and conduct was not found upto the expectation of the Management. Compensation and notice pay, along with the letter of termination of service was also sent to him and the discharge was after the Management had reviewed the working of the probationers on 08.10.2001 wherein it was noticed that the probationer was remaining absent, adversely affecting the working of the Company, doing illegal activities at the gate of the Company and affecting the industrial peace of the Company.

     

    The court held, the Management is within its right to discharge the workman from his services in view of his conduct during period of probation since the main object of appointment of a person on probation is to enable the employer to assess his suitability in the establishment during the probation period and afterwards. Hence, no regular enquiry is required in such matter since the termination is neither stigmatic nor against the conditions of employment.

    In another matter [DM, Rajasthan State Road Transport Corporation Vs. Kamruddin 2009 LLR 945] Supreme Court opined that dismissal of a probationer, for unsatisfactory work, will not be interfered by the courts.

     

    The HR function has to take up the responsibility of monitoring, guiding, counselling and assisting the probationers to cope up with the work requirements and also document the deficiencies, if any, found during the probationary period so as to enable the management to take an appropriate decision on the probationary workmen. If this is not done, the purpose for which the probationary period has been created will be defeated.

    Tags:

    Subscribe SBS AND COMPANY LLP updates via Email!