Objective
The Company is committed to providing a safe, respectful, inclusive, and professional work environment free from harassment, discrimination, intimidation, and retaliation. This policy aims to prevent and address all forms of workplace harassment and ensure compliance with applicable laws, including the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.
Key Components
1. Definitions
Sexual Harassment
Sexual harassment includes any unwelcome act or behaviour of a sexual nature, whether direct or implied, including but not limited to:
- Physical contact or advances.
- Requests or demands for sexual favours.
- Sexually coloured remarks or jokes.
- Display or sharing of sexually explicit content.
- Unwelcome verbal, non-verbal, or physical conduct of a sexual nature.
- Repeated unwanted attention, messages, or advances.
Verbal Harassment
Verbal harassment includes:
- Offensive comments or remarks.
- Insults, humiliation, or threats.
- Abusive language.
- Derogatory comments relating to gender, race, age, religion, disability, or other protected characteristics.
Physical Harassment
Physical harassment includes:
- Unwanted touching or physical contact.
- Physical intimidation.
- Assault or threats of violence.
- Invading an individual's personal space in a threatening manner.
Digital Harassment
Digital harassment includes:
- Inappropriate emails, messages, or social media communications.
- Sharing offensive, discriminatory, or sexually explicit content electronically.
- Cyberbullying or online stalking.
- Unauthorized recording or sharing of personal information or images.
2. Complaint Mechanism
Reporting Channels
Any employee who believes they have experienced or witnessed harassment may report the incident through any of the following channels:
- Reporting Manager.
- Human Resources Department.
- Company grievance email or complaint portal.
Employees are encouraged to report incidents promptly to facilitate timely action.
Confidentiality
- All complaints, investigations, and related proceedings will be handled with strict confidentiality.
- Information will be shared only with individuals directly involved in the investigation process.
- Unauthorized disclosure of complaint-related information may result in disciplinary action.
3. Investigation Process
Internal Committee (IC)
In accordance with the POSH Act, the Company shall constitute an Internal Committee comprising:
- A Presiding Officer who is a senior female employee.
- At least two employee members committed to women's welfare or possessing legal/social work knowledge.
- One external member familiar with issues relating to sexual harassment.
Timelines
- Complaint to be filed within 1 months from the date of the incident (or last incident in case of repeated occurrences).
- Preliminary review upon receipt of complaint.
- Investigation to be completed within 30 days.
- Recommendations submitted within 10 days of completion of the inquiry.
- Employer to implement recommendations within 30 days.
Due Process
The investigation process shall ensure:
- Fair and impartial inquiry.
- Opportunity for both parties to present evidence and witnesses.
- Protection of the rights of all parties involved.
- Decisions based on facts, evidence, and applicable law.
4. Protection Measures
Non-Retaliation
The Company strictly prohibits retaliation against any individual who:
- Files a complaint in good faith.
- Participates in an investigation.
- Acts as a witness.
- Supports a complainant during the process.
Any retaliatory action will be treated as misconduct and may result in disciplinary action.
Interim Relief
During the investigation, the Internal Committee may recommend interim measures including:
- Temporary transfer of either party.
- Change in reporting structure.
- Leave for the aggrieved employee as permitted under applicable laws.
- Restriction on contact between involved parties.
Such measures are intended to ensure safety and prevent further harassment during the inquiry process.
5. Disciplinary Action
Where allegations are substantiated, the Company may impose appropriate disciplinary measures, including:
- Written warning.
- Mandatory counselling or training.
- Suspension.
- Withholding promotion or salary increment.
- Transfer.
- Termination of employment.
- Legal action where applicable.
6. Employee Responsibilities
All employees are expected to:
- Treat colleagues with dignity and respect.
- Refrain from any form of harassment or discriminatory behaviour.
- Cooperate during investigations.
- Participate in POSH awareness and training programs.
- Report incidents of harassment promptly.
7. Compliance
The Company shall comply with the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and any subsequent amendments.
The Company shall:
- Constitute and maintain an Internal Committee (IC).
- Conduct regular POSH awareness and sensitization programs.
- Maintain records of complaints and resolutions.
- Submit statutory reports as required under applicable law.
- Display POSH policy and Internal Committee details at the workplace.
The Company maintains a zero-tolerance approach toward workplace harassment and is committed to ensuring a safe, respectful, and inclusive workplace for all employees.