POSH POLICY

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act) was enacted as a comprehensive legislation to ensure a safe, secure environment, free from sexual harassment to every woman.

The corporate POSH (Prevention of Sexual Harassment) Policy is applicable to all employees of the company, including women at the workplace, irrespective of their age. Additionally, it aims to provide protection to women employees not only within the premises of the company but also during any work-related travel or activities.

The purpose of the POSH Policy is to provide a safe working environment for women in the Company, safeguarding them from any form of harassment by individuals they come into contact with at the workplace. According to the policy, every company is required to constitute an Internal Complaints Committee in accordance with Sexual Harassment Laws to address any complaints of sexual harassment filed by an Aggrieved Woman.

The company must ensure the comprehensive implementation of this policy by preventing acts of sexual harassment, facilitating proper reporting and prompt redressal of complaints, and establishing follow-up procedures. Additionally, it should foster an environment that promotes awareness among employees regarding sexual harassment in its various forms and sensitizes them to the provisions outlined in the Sexual Harassment Laws.

Defining Sexual Harassment:

This policy aims to safeguard women employees from acts of sexual harassment. Sexual harassment encompasses any one or more of the unwelcome acts or behaviors, whether direct or implied, including:

• Physical contact and advances.
• Demands or requests for sexual favors.
• Making sexually colored remarks.
• Sending pornography videos or showing them.
• Any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature.

Additionally, the following circumstances, among others, if they occur or are present in relation to or connected with any of the above acts or behaviors of sexual harassment, will also constitute sexual harassment:

• Implied or explicit promise of preferential treatment in her employment; or
• Implied or explicit threat of detrimental treatment in her employment; or
• Implied or explicit threat about her present or future employment status; or
• Interference with her work or creating an intimidating or offensive or hostile work environment for her; or
• Humiliating treatment likely to affect her health or safety.

The Company has constituted an Internal Complaints Committee in accordance with Section 4 of the Act. The Presiding Officer of the Committee and other members comprising the Committee who will be nominated by the Company shall hold office in accordance with the Sexual Harassment Laws and shall be notified by the Company from time to time.

Complaint:

An Aggrieved Woman may make, in writing, a complaint of Sexual Harassment to the Committee, within a period of three months from the date of incident and in case of a series of incidents, within a period of three months from the date of the last incident.

Provided that where such complaint cannot be made in writing, the Presiding Officer or any Member of the Committee, as the case may be, shall render all reasonable assistance to the Aggrieved Woman for making the complaint in writing.

Provided further that the Committee may, for reasons recorded in writing, extend the time limit not exceeding three months if satisfied that circumstances prevented the Aggrieved Woman from filing a complaint within the initial period.

Settlement:

The Committee may, before initiating an inquiry on the Complaint and at the request of the Aggrieved Woman, take steps to settle the matter between her and the Respondent through conciliation. However, no monetary settlement shall be made the basis of conciliation.

Inquiry:

In case no settlement is arrived at and the Respondent is an Employee, the Committee shall proceed to inquire into the complaint in the manner provided under the Service Rules and Sexual Harassment Laws.

Internal Complaint Committee (ICC) for POSH: