1.0
COMMITMENT:
Our Company is committed to providing work environment that ensures every employee is treated with dignity and respect and afforded equitable treatment.
The Company is also committed to promoting a work environment that is conducive to the professional growth of its employees and encourages equality of work area.
The Company will not tolerate any form of harassment /sexual harassment and is committed to take all necessary steps to ensure that its employees are not subjected to any form of harassment.
2.0
SCOPE:
This policy applies to all employees (full-time, part-time, trainees and those on contractual assignments) of the Company including all subsidiaries and affiliated companies at their workplace or at client sites. The Company will not tolerate sexual harassment, if engaged in by clients or by employees or any other business associates.
The workplace includes:
01.)
All offices or other premises where the Company’s business is conducted
02.)
All company-related activities performed at any other site away from the
Company’s premises.
03.)
Any social, business or other functions where the conduct or comments may have an adverse impact on the workplace or workplace relations.
3.0
DEFINITION OF SEXUAL HARASSMENT
Sexual harassment may be one or a series of incidents involving unsolicited and unwelcome sexual advances, requests for sexual favours, or any other verbal or physical conduct of sexual nature.
Sexual Harassment at the workplace includes:
01.)
unwelcome sexual advances (verbal, written or physical),
02.)
demand or request for sexual favours,
03.)
any other type of sexually-oriented conduct,
04.)
verbal abuse or ‘joking’ that is sex-oriented,
05.)
any conduct that has the purpose or the effect of interfering with an individual’s work performance or creating an intimidating, hostile or offensive work environment and/or submission to such conduct
4.0
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.
5.0
COMPLAINT MECHANISM:
An appropriate complaint mechanism in the form of “Complaints Committee” has been created in the Company for time-bound redressal of the complaint made by the victim.
6.0
COMPLAINTS COMMITTEE:
The Company has instituted a Complaints Committee for redressal of sexual harassment complaint (made by the victim) and for ensuring time bound treatment of such complaints.
Initially, and till further notice, the Complaints Committee will comprise of the following three members:
01.)
Mrs Nidhi Kasliwal – Managing Director
02.)
Mrs Richa Trivedi – Head HR
03.)
Mr. Rajesh Jha – Audit Manager
The Complaints Committee is responsible for:
01.)
Investigating every formal written complaint of sexual harassment
02.)
Taking appropriate remedial measures to respond to any substantiated allegations of sexual harassment
03.)
Discouraging and preventing employment-related sexual harassment
7.0
PROCEDURES FOR RESOLUTION, SETTLEMENT OR PROSECUTION OF ACTS OF SEXUAL HARASSMENT:
The Company is committed to providing a supportive environment to resolve concerns of sexual harassment as under:
A.)
Informal Resolution Options
When an incident of sexual harassment occurs, the victim of such conduct can communicate their 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, the victim can bring their concern to the attention of the Complaints Committee for redressal of their grievances. The Complaints Committee will thereafter provide advice or extend support as requested and will undertake prompt investigation to resolve the matter.
01.)
An 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 Complaints Committee constituted by the Management. The complaint shall have to be in writing and can be in form of a letter, submitted within 3 months from the date of the incident and in case of a series of incidents, within a period of 3 months from the date of the last incident. The Complaints Committee can extend the timeline for filing the complaint, for reasons to be recorded in writing, by a period of 3 months. Alternately, the employee can send complaint through an email. The employee is required to disclose their name, department, division and location they are working in, to enable the committee member to contact them and take the matter forward.
02.)
The Complaints Committee will proceed to determine whether the allegations (assuming them to be true only for the purpose of this determination) made in the complaint fall under the purview of Sexual Harassment, preferably within 30 days from receipt of the complaint.
In the event, the allegation does not fall under the purview of Sexual Harassment or the allegation does not constitute an offence of Sexual Harassment, the committee will record this finding with reasons, and communicate the same to the complainant.
03.)
If the Complaints Committee determines that the allegations constitute an act of sexual harassment, he/ she will proceed to investigate the allegation.
04.)
Where such conduct, on the part of the accused, amounts to a specific offence under the law, the Company shall initiate appropriate action in accordance with law by making a complaint with the appropriate authority.
05.)
The Complaints Committee shall conduct such investigations in a timely manner and decide the corrective action to be taken on mutual discussion.
Corrective action may include any of the following:
b.)
Counseling
Written warning to the perpetrator and a copy of it maintained in the employee’s file.
c.)
Change of work assignment / transfer for either the perpetrator or the victim.
d.)
Suspension or termination of services of the employee found guilty of the offence
06.)
In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for appropriate disciplinary action by the Management.
8.0
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 the investigatory process to the extent practicable and appropriate under the circumstances.
9.0
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.
10.
PROTECTION TO COMPLAINANT / VICTIM:
The Company is committed to ensuring that no employee who brings forward a harassment concern is subject to any form of reprisal. Any reprisal will be subject to disciplinary action.
The Company will ensure that the victim or witnesses are not victimized or discriminated against while dealing with complaints of sexual harassment.
However, anyone who abuses the procedure (for example, by maliciously putting an allegation knowing it to be untrue) will be subject to disciplinary action.
11.
CONCLUSION:
In conclusion, the Company reiterates its commitment to providing its employees, a workplace free from harassment/ discrimination and where every employee is treated with dignity and respect.
