SEXUAL HARRASSMENT POLICY
Table of Contents
1. POLICY STATEMENT .................................................................................................................. 2
2. ACRONYMS ................................................................................................................................2
3. APPLICABILITY............................................................................................................................ 2
4. SCOPE..........................................................................................................................................3
5. DEFINITIONS ...............................................................................................................................3
6. PREVENTION ACTION ................................................................................................................ 4
7. REDRESSAL COMPLAINTS COMMITTEE...................................................................................... 4
8. PROCEDURE FOR DEALING WITH COMPLAINTS........................................................................ 5
8.1 FILING OF A COMPLAINT......................................................................................................... 5
8.2 PROCESS OF ENQUIRY ............................................................................................................ 7
8.3 COMPLAINT OF SEXUAL HARASSMENT................................................................................... 9
8.4 DECISION AND ACTION.............................................................................................................9
9. DETERMINATION OF COMPENSATION...................................................................................... 11
10. PROHIBITION OF PUBLICATON OR MAKING KNOWN CONTENT OF COMPLAINT OR INQUIRY ...................................................................................................................................................... 11
11. DUTIES OF THE EMPLOYER.................................................................................................... 11
12. SEXUAL HARRASMENT AND CLIENT/PARTNERS ................................................................... 12
13. POLICY IMPLEMENTATION AND REVIEW.............................................................................. 12
14. ANNEXURES........................................................................................................................... 12
14.1 ANNEXURE I – RESPONSIBILITY OF ASSOCIATES ................................................................. 12
14.2 ANNEXURE II – GUIDELINES FOR INTERNAL COMPLAINTS COMMITTEE............................. 14
As a Company, we are committed to conducting and governing ourselves with ethics, transparency and accountability and to this, we have developed governance structures, practices and procedures that ensure that ethical conduct at all levels is promoted across our value chain. It is thus in acknowledgement of and consonance with these values, that we are dedicated to ensuring that the work environment at all our locations is conducive to fair, safe and harmonious relations, based on mutual trust and respect, between all the associates of the Company. We also strive to guarantee a safe and welcoming environment to all those who visit any of our locations in any capacity, such as customers, vendors etc. Discrimination and harassment of any type is strictly prohibited. We wish to promote and maintain this culture to ensure that associates of the Company do not engage in practices that are abusive in any form or manner whatsoever.
The Company aims to provide a safe working environment and prohibits any form of sexual harassment. Hence any act of sexual harassment or related retaliation against or by any associate is unacceptable. This policy therefore, intends to prohibit such occurrences and also details procedures to follow when an associate believes that a violation of the policy has occurred within the ambit of all applicable regulations regarding sexual harassment.
Making a false complaint of sexual harassment or providing false information regarding a complaint will also be treated as a violation of policy.
All managers to ensure that they themselves as well as their team, including new joinees, are aware of the Policy on Prevention of Sexual Harassment in place and strictly adhere to it.
Company will promptly investigate all complaints and take appropriate action, up to and including termination of employment.
Term/ Acronym Explanation
- HR Human Resources
- NGO Non-Governmental Organization
- RM Reporting Manager
- POSH Prevention of Sexual Harassment
This policy will extend to all associates of the Company including those employed on regular, temporary, ad-hoc or daily wage basis, either directly or through an agent, including a contractor, whether for the remuneration or not, or working on a voluntary basis or otherwise, whether the terms of employment are express or implied (hereinafter referred to as ―Associates‖).
The policy also extends to those who are not employees of the Company, such as customers, visitors, vendors, suppliers , contract worker, probationer, trainee, apprentice or called by any other such name, but are subjected to sexual harassment at the Premises (defined hereinafter) of the Company.
The scope of the Policy is restricted to the following for all Associates:
- business locations of the Company
- any external location visited by Associates due to or during the course of their employment with the Company such as business locations of other Companies/entities, guest houses etc.
- any mode of transport provided by the Company (or a representative of the Company) for undertaking a journey to and from the aforementioned locations
- at any other location whether in India or outside India.
―Aggrieved Associate‖ means in relation to a workplace, any individual, of any age whether employed in the Company or not, who alleges to have been subjected to any act of Sexual
Harassment by the associate of the Company.
―Employer‖ means in any workplace, any person responsible for the management, supervision and control of the Workplace.
―Sexual harassment" includes any unwelcome sexually determined behavior (direct or implied) such as physical contact and advances, unwelcome communications or invitations, demand or request for sexual favors, sexually cultured remarks, showing pornography, creating a hostile work environment and any other unwelcome ―sexually determined behavior‖ (physical, verbal or non-verbal conduct) of a sexual nature.
―Sexual Harassment‖ would also mean:
- Quid pro quo sexual harassment, which means something in return or an exchange of one thing for another.
- In the workplace, quid pro quo sexual harassment takes place if sexual favors are asked in exchange for any kind of special treatment on the job. Threatening an Associate about his/her present or future employment status if he/she does not consent to such sexual advances or a favor also amounts to sexual harassment. The act of asking may either be verbal or implied and the ‗sexual conduct may be verbal or physical. But, in either case, it must be unwelcome
- For e.g.: Direct or implied requests or offers by any associate for sexual favors in exchange for actual or promised job benefits such as favorable reviews, salary increases, promotions, increased benefits, or continued employment constitutes sexual harassment.
- Hostile work environment includes
- Hostile environment sexual harassment occurs when either speech or conduct of a sexual nature takes place, and is seen or perceived as offensive and interferes with the work performance of the recipient, or any one or more Associates
- Hostile environment sexual harassment may also include intimidating or harassing conduct that is directed at an individual, or a group of individuals
- It will also mean related retaliation which includes marginalizing someone in the workplace with regard to his / her roles and responsibilities, socially ostracizing, intimidating someone physically, psychologically, and emotionally or someone close to or related to the victim, to the extend the humiliation or intimidation affects the health or safety.
This is only an indicative list of the possible acts which could be treated as sexual harassment and is in no way intended to be construed as an exhaustive list.
