1. Objective

The objective of this Policy is to create a safe, secure, and enabling work environment that is free from sexual harassment. The Company is committed to ensuring that every employee is treated with dignity and respect, in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and Rules, 2013 (hereinafter referred to as the POSH Act).

2. Scope

This Policy applies to:

• All employees (permanent, temporary, contractual, interns, consultants, and trainees) of the Company.
• All workplaces, including branch offices, client locations, virtual work environments, and work-related events, whether within or outside office premises.

3. Definition of Sexual Harassment

• As per Section 2(n) of the POSH Act, “sexual harassment” includes any one or more of the following unwelcome acts or behavior (directly or by implication):
• Physical contact or advances;
• A demand or request for sexual favors;
• Making sexually colored remarks;
• Showing pornography; or
• Any other unwelcome physical, verbal, or non-verbal conduct of sexual nature.
• Examples may include inappropriate touching, suggestive comments, sexually explicit jokes, stalking, or sending offensive messages.

4. Definition of Aggrieved Woman

An “Aggrieved Woman” means any woman (employee, client, vendor, or visitor) who alleges to have been subjected to sexual harassment at the workplace.

5. Internal Committee (IC)

• As per Section 4 of the POSH Act, the Company shall constitute an Internal Committee (IC) comprising:
• Presiding Officer – A senior woman employee.
• Two Employee Members – Preferably with social work or legal knowledge.
• External Member – From an NGO or association committed to women’s causes.

The IC will have a tenure of three years.

6. Roles and Responsibilities of the IC

• Receive and acknowledge complaints of sexual harassment.
• Conduct inquiries in a fair, confidential, and time-bound manner.
• Recommend disciplinary or corrective action to the employer.
• Submit annual reports to the employer and the District Officer.

7. Procedure for Filing Complaints

• Complaints should be made in writing within three months of the incident.
• The complaint may be submitted to the Presiding Officer or any IC member.
• If the aggrieved woman cannot make a written complaint, the IC will assist her.
• The IC will acknowledge receipt and initiate inquiry procedures within 7 days.

8. Inquiry Process

• The IC shall follow principles of natural justice.
• Both parties will be given an opportunity to present their case, evidence, and witnesses.
• Inquiry to be completed within 90 days, and the IC shall submit its report within 10 days of completion.
• The employer shall act upon the recommendations within 60 days.

9. Interim Relief

• During the pendency of inquiry, the IC may recommend:
• Transfer of either party;
• Grant of leave up to three months to the aggrieved woman;
• Any other relief deemed appropriate.

10. Action on Complaint

1. If allegations are proved, disciplinary action may include written apology, warning, withholding promotion, termination, etc.
2. If allegations are malicious or false, appropriate action will be taken against the complainant as per Section 14 of the Act.

11. Confidentiality

All details related to the complaint, witness statements, and inquiry proceedings shall be kept strictly confidential, except where disclosure is required by law.

12. Awareness and Training

• The Company shall conduct regular awareness sessions for employees and training for IC members.
• A copy of this Policy shall be available at all workplaces and shared with all employees.

13. Annual Report

• The IC shall prepare an annual report containing:
• Number of complaints received and disposed of;
• Cases pending for more than 90 days;
• Workshops conducted; and
• Nature of action taken.