INTRODUCTION
In accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and
Redressal) Act, 2013 the Company has framed a Anti-Sexual Harassment policy for prevention of
Sexual Harassment at Workplace and adopted the same w.e.f 09th April, 2015. Vide notification
dated 9th December, 2013 Ministry of Women and Child Development have introduced Sexual
Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013.
The objective of the policy is to provide its women employees, a workplace, free from harassment/
discrimination and every employee is treated with dignity and respect.
COMMITMENT
Our Company is committed to provide a work environment that ensures every woman employee is
treated with dignity and respect and afforded equitable treatment.
The Company is also committed to promote a work environment that is conducive to the
professional growth of its women employees and encourages equality of opportunity.
The Company will not tolerate any form of sexual harassment and is committed to take all
necessary steps to ensure that its women employees are not subjected to any form of harassment.
SCOPE
This policy applies to all categories of employees of the Company, including permanent
management and workmen, temporaries, trainees and employees on contract at its workplace or at
client sites. The Company will not tolerate sexual harassment, if engaged in by clients or by
suppliers or any other business associates.
The workplace includes:
- All offices or other premises where the Company’s business is conducted.
- All company-related activities performed at any other site away from the Company’s premises.
- Any social, business or other functions where the conduct or comments may have an adverse
impact on the workplace or workplace relations.
DEFINITIONS
Aggrieved person: Any person (employed, associated and visiting the Company) who
complained of sexual harassment.
Respondent: Any person (employed, associated and visiting the Company) against whom
aggrieved person complained.
Workplace: Includes all offices and branches in the Company, all instances reported within
the Company and in any place visited by the employee arising out of or during the course of
the employment including transportation provided by the Company for undertaking such
journey.
Sexual Harassment: includes any one or more of the following unwelcome acts or behavior
(whether directly or by implication) namely:-
i. Physical contact and advances; or
ii. A demand or request for sexual favors; or
iii. Making sexually coloured remarks; or
iv. Showing pornography; or
v. Any other unwelcome physical, verbal or non-verbal conduct of sexual nature.
RESPONSIBILITIES REGARDING SEXUAL HARASSMENT
All employees of the Company have a personal responsibility to ensure that their behavior is not
contrary to this policy. All employees are encouraged to reinforce the maintenance of a work
environment free from sexual harassment.
COMPLAINT MECHANISM
Whether or not such conduct constitutes an offence under law or a breach of the service rules, an
appropriate complaint mechanism in the form of “Internal Complaints Committee” has been
created in the Company for time-bound redressal of the complaint made by the victim.
INTERNAL COMPLAINTS COMMITTEE
The Company has instituted an Internal Complaints Committee for redressal of sexual harassment
complaint (made by the victim) and for ensuring time bound treatment of such complaints. In
accordance with the sexual Harassment of Women at Workplace (Prevention, Prohibition and
Redressal) Act, 2013, the Internal Complaints Committee will comprise of the following:
- Chairperson – Shall be a woman employed at a senior level at workplace amongst the
employees - Two members – Not less than 2 members from amongst employees preferably committed to
the cause of women OR who have had experience in social work OR have legal knowledge. - One Member – One member shall be from amongst Non-governmental organizations OR
associations committed to the cause of women OR a person familiar with the issues relating to
sexual harassment.
The Internal Complaints Committee is responsible for:
Investigating every formal written complaint of sexual harassment.
Taking appropriate remedial measures to respond to any substantiated allegations of sexual
harassment.
Discouraging and preventing employment-related sexual harassment.
PROCEDURES FOR RESOLUTION, SETTLEMENT OR PROSECUTION OF ACTS OF SEXUAL
HARASSMENT
The Company is committed to providing a supportive environment in which the concerns of sexual
harassment shall be resolved as follows:
A. INFORMAL RESOLUTION OPTIONS
- When an incident of sexual harassment occurs, the victim of such conduct can communicate her
disapproval and objections immediately to the harasser and request the harasser to behave
decently. - If the harassment does not stop or if victim is not comfortable with addressing the harasser
directly, she can bring her concern to the attention of the Internal Complaints Committee for
redressal of her grievances. The Internal Complaints Committee will thereafter provide advice or
extend support as requested and will undertake prompt investigation to resolve the matter.
B. COMPLAINTS - Any employee with a harassment concern, who is not comfortable with the informal resolution
options or has exhausted such options, may make a formal complaint to the Chairperson of the
Internal Complaints Committee constituted by the Management. - The complainant shall submit 6(six) copies of the Complaint to the Complaint Committee along
with supporting documents and the names and addresses of the witnesses in writing and can be in
form of a letter, preferably within 3months from the date of occurrence of the alleged incident, sent
in a sealed envelope. Alternately, the employee can send complaint through an email. The employee
is required to disclose her name, department, division and location she is working in, to enable the
Chairperson to contact her and take the matter forward. - The Complaint Committee shall send 1(one) of the copies received from the aggrieved woman to
the accused (respondent) within a period of 7 working days. - The Accused (respondent) shall file his reply to the Complaint along with supporting documents
and the names and addresses of the witnesses, within a period not exceeding 10 working days from
the date of receipt of the documents. - The Complaint committee have the right to terminate the inquiry proceedings or to give an ex-
parte decision on the complaint, if the Aggrieved (complainant) or Accused (respondent) fails,
without sufficient cause, to present herself or himself for 3 consecutive hearings convened by the
Chairperson, as the case may be, provided that such termination or ex-parte order may not be
passed without giving a notice in writing, 15 days in advance, to the party concerned. In conducting
the inquiry, a minimum of 3 Members of the Complaints Committee including the chairperson, as
the case may be, shall be present.
- The parties shall not be allowed to bring in any legal practitioner to represent them in their case
at any stage of the proceedings before the Complaints Committee. - The Internal Complaints Committee shall conduct such investigations in a timely manner and
shall submit a written report containing the findings and recommendations to the Employer as
soon as practically possible and in any case, not later than 10 days from the date of completion of
inquiry. The Employer shall act upon the recommendation within 60 days of its receipt by him. - The Complaint’s Committee report will also be made available to concerned parties.
MANNER OF TAKING ACTION AGAINST THE RESPONDENT
Where the Complaints Committee arrives at the conclusion that the allegation against the
respondents been proved, it shall recommend to the employer to take action which may include the
following:
a. Written apology;
b. Warning;
c. Reprimand or Censure;
d. Withholding of Promotion;
e. Withholding of pay rise or increments; or
f. Terminating the respondent from service; or
g. Undergoing a counseling session or carrying out community service.
PUNISHMENT FOR FALSE OR MALICIOUS COMPLAINT AND FALSE EVIDENCE
Where the Internal Complaints Committee arrives at a conclusion that the allegation against the
respondent is malicious or the aggrieved woman or any other person making the complaint has
made the complaint knowing it to be false or the aggrieved woman or any other person making the
complaint has produced any forged or misleading document, it may recommend to the employer to
take action in accordance with the provisions of the service rules applicable to her or him.
CONFIDENTIALITY
The Company understands that it is difficult for the victim to come forward with a complaint of
sexual harassment and recognizes the victim’s interest in keeping the matter confidential.
To protect the interests of the victim, the accused person and others who may report incidents of
sexual harassment, confidentiality will be maintained throughout any investigatory process to the
extent practicable and appropriate under the circumstances.
ACCESS TO REPORTS AND DOCUMENTS
All records of complaints, including contents of meetings, results of investigations and other
relevant material will be kept confidential by the Company except where disclosure is required
under disciplinary or other remedial processes.
CONCLUSION
In conclusion, the Company reiterates its commitment to providing its women employees, a
workplace free from harassment/ discrimination and where every employee is treated with dignity
and respect.