In accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 the Company has framed an Anti-Sexual Harassment policy for prevention of Sexual Harassment at Workplace and adopted the same w.e.f 14th March, 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) whocomplained of sexual harassment.
Respondent: Any person (employed, associated and visiting the Company) against whomaggrieved person complained.
Workplace: Includes all offices and branches in the Company, all instances reported withinthe 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:-

Physical contact and advances; or
A demand or request for sexual favors; or
Making sexually coloured remarks; or
Showing pornography; or
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 theemployees
Two members – Not less than 2 members from amongst employees preferably committed tothe 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 ORassociations 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:

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 the 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.
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:

Written apology;
Warning;
Reprimand or Censure;
Withholding of Promotion;
Withholding of pay rise or increments; or
Terminating the respondent from service; or
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.