[Two threads merged and similar OPs merged].
I can't comment on the specific procedure but, in general, there is no absolute prohibition against turns below 400ft. Indeed, many terrain-critical departures are based on turns from the runway head or a waypoint prior to 400 ft ..
Perhaps you might be confusing this with the certification requirement that the OEI third segment minimum height is 400 ft above runway elevation ? .. regardless of whether there be a turn or not ...