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Smarsh POSH Policy _2020

The POSH Policy outlines Smarsh India's commitment to preventing sexual harassment in the workplace, detailing definitions, procedures for complaints, and the establishment of an Internal Complaint Committee. It emphasizes the importance of a safe work environment and compliance with the Sexual Harassment of Women at Workplace Act, 2013. The policy includes mechanisms for reporting, investigating complaints, and protecting the dignity of all employees involved.

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0% found this document useful (0 votes)
22 views

Smarsh POSH Policy _2020

The POSH Policy outlines Smarsh India's commitment to preventing sexual harassment in the workplace, detailing definitions, procedures for complaints, and the establishment of an Internal Complaint Committee. It emphasizes the importance of a safe work environment and compliance with the Sexual Harassment of Women at Workplace Act, 2013. The policy includes mechanisms for reporting, investigating complaints, and protecting the dignity of all employees involved.

Uploaded by

harshkumarjune
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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POSH POLICY

HRPOL/GEN/00113.1

PREVENTION OF SEXUAL HARASSEMENT (POSH) Policy

EFFECTIVE: [1st January 2020]

Document Attributes

Document Number HRPOL/GEN/00113.1

Original Signatory Smarsh India HR

Approved By Smarsh India SVP & MD / HR

Policy Owner Smarsh India HR

Document Version Control

Version Number Date Change (Approved By) Change Description

HRPOL/GEN/00111.0 30th November 2017 N/A Initial Version

Additional clauses added,


1st January 2020 Smarsh India SVP & MD / HR
HRPOL/GEN/00111.1 change in committee

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Contents

1. OBJECTIVE ......................................................................................................................................... 3
2. DEFINITIONS & ABBREVIATIONS ....................................................................................................... 3
3. SCOPE ................................................................................................................................................ 3
4. DEFINITION OF SEXUAL HARASSMENT ............................................................................................. 4
5. CONSENSUAL SEXUAL RELATIONSHIPS ............................................................................................. 4
6. SEXUAL HARASSMENT AS PER LAW OF THE LAND ........................................................................... 4
7. INTERNAL COMPLAINT COMMITTEE ................................................................................................ 5
8. PROCEDURE FOR RESOLUTION OF COMPLAINTS SETTLEMENT OR PROSECUTION OF ACTS OF
SEXUAL HARASSMENT .............................................................................................................................. 6
9. POLICY REVIEW & CHANGE AUTHORIZATION .................................................................................. 9
10. PUNISHMENT FOR FALSE OR MALICIOUS COMPLAINT AND FALSE EVIDENCE ................................ 9
11. CONFIDENTIALITY.............................................................................................................................. 9
12. PROTECTION AGAINST RETALIATION.............................................................................................. 10
13. ACCESS TO REPORTS AND DOCUMENTS......................................................................................... 10
14. DUTIES AND RESPONSIBILITIES OF THE EMPLOYER........................................................................ 10
15. ANNEXURE ...................................................................................................................................... 11

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1. OBJECTIVE

Smarsh is committed to create and maintain a secure work environment wherein its Employees (defined below),
agents, vendors and business partners can work and pursue business together in an atmosphere free of
harassment, exploitation and intimidation caused by acts of Sexual Harassment within the Workplace (defined
below). We value each Employee working with us and wish to protect their dignity and self-respect. Smarsh and its
Employees have a shared responsibility in continuing to a mature and respectful work environment.

The policy has been formulated in accordance with the provisions of the Sexual Harassment of Women at
Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“Act”).

2. DEFINITIONS & ABBREVIATIONS

“Complainant” or “Aggrieved Person” means in relation to a Workplace, an Employee of any age, whether or not
employed directly by Smarsh, who alleges to have been subjected to any act of Sexual Harassment by the
Respondent (defined below).

“Employer” means (i) any person responsible for the management, supervision and control of the Workplace; or
(ii) the relevant person discharging contractual obligations with respect to the Employees.

“Employee” means any person employed at the Workplace for any work, including all regular, permanent and
temporary employees, full-time or part time employees, consultants, interns, contractors, ad hoc or honorary
associates, probationers, trainees, apprentices by whatever name called, whether employed for remuneration or
not / working on a voluntary basis, or otherwise employed either directly or through an agent, and with or without
the knowledge of Smarsh. In case of an allegation of Sexual Harassment against a contractor, Smarsh will work with
the direct employer of the alleged offender/concerned vendor to decide how the matter should be dealt with.

“Respondent” means a person against whom an Aggrieved Person has made a written complaint of Sexual
Harassment as set forth herein.

“Workplace” means: (i) any office, branch, unit, department, or undertaking established, owned, controlled, or
wholly or substantially financed by funds provided directly or indirectly by Smarsh or any affiliate entities (if any);
(ii) any place visited by an Employee arising out of or during the course of employment (such as meetings at third
party premises, offsite meetings and public venues), including transportation provided by Smarsh for undertaking
such journey; and/or (iii) any other location provided for under the Act.

3. SCOPE

The scope of this policy is to prevent instances of Sexual Harassment at the Workplace, to address complaints and
provide redress, to set out procedures for resolution, settlement and/or prosecution of acts of Sexual Harassment at
the Workplace. The scope of the policy extends to the entire operations of Smarsh and is deemed to be part of the
service conditions of all Employees (defined below).

This policy is applicable to all Employees of Smarsh in India and any allegations of Sexual Harassment made by an
Employee against another Employee or client, supplier or business associate of Smarsh, or by such client, supplier or
business associate or visitor against an Employee, if the conduct occurred at the Workplace, or during the course of the
Employee's work for Smarsh.

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4. DEFINITION OF SEXUAL HARASSMENT

Sexual Harassment maybe 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 (whether directly or by
implication).

Sexual Harassment would mean and includes any of the following:


(i) Physical contact and advances; or
(ii) A demand or request for sexual favours;
(iii) Making sexually coloured remarks;
(iv) Showing pornography;
Any other unwelcome physical, verbal or non-verbal conduct of sexual nature.

The following circumstances, among other circumstances, if it occurs or is present in relation to or connected with
any act or behaviour of sexual harassment may amount to sexual harassment:

(i) Implied or explicit promise of preferential treatment in employment; or


(ii) Implied or explicit threat of detrimental treatment in employment; or
(iii) Implied or explicit threat about present or future employment status; or
(iv) Any unwelcome sexual determined behavior involving verbal, non-verbal or physical conduct such as
sexually colored remarks, jokes, letters, phone calls, SMS or email communication, gestures, showing of
pornography, lucid stares, physical contact or molestation, stalking, sounds, display or pictures, signs,
verbal or non-verbal communication which offend the individual’s sensibilities and affects his or her
performance at the workplace; or
(v) Eve-teasing, innuendos and taunts, physical confinement against one’s will and likely to intrude upon the
individual’s privacy; or
(vi) Any act or conduct by a person in authority which creates the environment at workplace hostile or
intimidating to a person; or
(vii) interference with work or offensive work environment; or

(viii) any other behavior of a sexual nature that might reasonably be expected or be perceived to cause offence
or humiliation or humiliating treatment likely to affect the person’s health or safety.

5. CONSENSUAL SEXUAL RELATIONSHIPS

Smarsh discourages romantic or sexual relationships between a member of Management or other supervisory
Employee and his or her staff (an employee who reports directly or indirectly to that person); as such a relationship
could lead to conflicts of interest at work.

It is therefore in the best interest of all concerned, that if there is such a relationship, the involved parties must notify
the Head HR of the Smarsh, so that the reporting chain can be altered to ensure that no direct or indirect reporting
relationship continues.

6. SEXUAL HARASSMENT AS PER LAW OF THE LAND

In countries where local laws/regulations have clearly defined ‘sexual harassment’ and procedures to address any
complaint relating to it, in such location the interpretation of sexual harassment and the investigation norms shall be
guided in accordance with the local laws/regulations, as applicable.

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7. INTERNAL COMPLAINT COMMITTEE

Smarsh has constituted a committee for redressal of Sexual Harassment complaints and for ensuring time bound
treatment of such complaints (“Internal Committee” or “Committee”). The Internal Committee will comprise 4
members; and in no circumstance will the membership of the Committee fall below 4 (four). At least half of the
members of the Committee shall be women, at all times. The Committee shall consist of the following members:

(i) presiding officer who shall be a senior woman Employee of Smarsh (“Presiding Officer”);
(ii) not less than 2 (two) members from amongst Employees preferably committed to the cause of women or who have
had experience in social work or have legal knowledge; and
(iii) 1 (one) member from amongst non-governmental organizations or associations committed to the cause of women
or an external counsel familiar with the issues relating to Sexual Harassment.

(collectively the “Investigating Members” and individually, an “Investigating Member”)

The names and contact details of the current members of the Internal Committee are set out below. Each
Investigating Member shall hold office for a term of 3 (three) years (“Term”) from the date of appointment of such
Investigating Member. However, the Employer may temporarily extend the Term of any Investigating Member in
order to dispose of any pending complaints of Sexual Harassment.

Internal Complaint Committee

Ms. Poonam Bajaj Chairperson

Mr. Sridhar Vutukuri Member of the Committee

Ms. Suzanne Rudnitzki Member of the Committee

Ms. Ivana Chatterjee Member of the External

The Employer may remove an Investigating Member and such Investigating Member shall cease to hold office if he/she is
found to have been involved in any action or situation that is immoral and unbecoming of an Employee. The following is
an indicative and non-exhaustive list of the situations in which an Investigating Member may be removed from office by
the Employer:

(i) if an Investigating Member leaks or publishes any information regarding any complaint of Sexual Harassment whether
disposed of or pending, including the names of the Aggrieved Person, Respondent, witnesses, etc.;
(ii) if an Investigating Member is convicted of an offence or is the subject of an inquiry into any offence under any law,
which is pending;
(iii) if an Investigating Member is found guilty in any disciplinary proceedings or if disciplinary proceedings are pending
against such Investigating Member; or
(iv) if an Investigating Member has abused his/her position as an Investigating Member of the Committee thereby rendering
his/her continuance in office against the interests of Smarsh and its Employees.

The Committee is expected to provide a sound mechanism for redressal of grievances by:

(i) accepting and registering in due time, any complaint pertaining to Sexual Harassment;
(ii) conducting inquiry within the specified timelines and recommending to the Employer, any action to be taken against
the Respondent;
(iii) recommending to the Employer, the need for medical, psychological, and emotional assistance to the Aggrieved
Person, if found necessary;
(iv) seeking police or legal intervention wherever necessary; and
(v) keeping the entire proceedings confidential.

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The Committee shall have the same powers as are vested in a civil court under the Code of Civil Procedure, 1908 when trying
a suit in respect of the following matters, namely, summoning and enforcing the attendance of any person and examining
him/her on oath; requiring the discovery and production of documents; and any other matter which may be prescribed.

The Committee shall submit an annual report to the Employer containing details of the number of complaints of Sexual
Harassment received in the year, the number of complaints disposed of during the year, the number of complaints pending
for more than 90 (ninety) days, the number of workshops or awareness programs against Sexual Harassment carried out
and details of the action taken by the Employer after receiving the recommendations of the Committee.

It shall be the responsibility of the Committee to ensure that all allegations are dealt with timeously, with due seriousness
and confidentiality; and that the allegations are dealt with in a manner which achieves a resolution of the behaviour, rather
than proceeding in a mechanistic procedural manner.

8. PROCEDURE FOR RESOLUTION OF COMPLAINTS SETTLEMENT OR PROSECUTION OF ACTS OF SEXUAL HARASSMENT

Filing of a complaint:

If any Employee believes that he/she has been subjected to Sexual Harassment at the Workplace, he/she is free to file
a complaint by sending an e-mail to [email protected] which is accessible to all the
Investigating Members of the Internal Committee. The Employee may also contact the Presiding Officer or any
Investigating Member individually (contact details set out under this Policy) and file a written complaint. Except in case
of e-mail, the Complainant/Aggrieved Person should submit 6 (six) copies of the complaint to the Committee, along
with other supporting details including complete contact details of the Aggrieved Person and the name and address of
the witnesses, if any.

If the complaint cannot be made in writing for any reason, the Presiding Officer or any Investigating Member, as the
case may be, shall render all reasonable assistance to the Aggrieved Person for making the complaint in writing.
Notwithstanding the foregoing, the following designees may file a complaint on behalf of the Aggrieved Person:

(i) if the Aggrieved Person is unable to make a complaint on account of her/his physical incapacity, a complaint may
be filed by: her/his relative or friend, her/his co-worker; an officer of the National Commission for Woman or State
Women's Commission, or any person who has knowledge of the incident, with the written consent of the Aggrieved
Person;

(ii) in the event the Aggrieved Person is unable to make the complaint on account of her/his mental incapacity, the
complaint may be filed by her/his relative or friend, a special educator; a qualified psychiatrist or psychologist; the
guardian or authority under whose care she/he is receiving treatment or care, or any person who has knowledge
of the incident jointly with his/her relative or friend/ a special educator/ qualified psychiatrist or psychologist /
guardian or authority under whose care she/he is receiving treatment or care;

(iii) where the Aggrieved Person for any other reason is unable to make a complaint, a complaint may be filed by any
person who has knowledge of the incident, with her/his written consent; and/or

(iv) where the Aggrieved Person is dead, a complaint may be filed by any person who has knowledge of the incident
with the written consent of her/his legal heir.

The complaint should be made within 3 (three) months from the date of occurrence of the alleged incident and in case
of series of incidents, within a period of 3 (three) months from the date of the last incident. The Internal Committee

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may, at its sole discretion, extend this time limit by up to 3 (three) more months if it is satisfied that the circumstances
were such which prevented the Complainant from filing the complaint within a period of 3 (three) months

Further Action on The Complaint

Conciliation

The Internal Committee may, before initiating an inquiry and at the request of the Aggrieved Person, take steps to settle
the matter between the Aggrieved Person and the Respondent through conciliation, provided that no monetary
settlement shall be made as a basis of conciliation.

Where a settlement has been arrived, as stated above, the Internal Committee shall record the settlement so arrived
at and forward the same to Smarsh to take action as specified in the recommendation. The Aggrieved Person and the
Respondent shall also receive copies of the settlement, as recorded.

(i) Where a settlement is arrived at, no further inquiry shall be conducted by the Internal Committee.

(ii) Where the Aggrieved Person subsequently informs the Internal Committee that any term or condition of the
settlement arrived at as part of the conciliatory proceedings, has not been complied with by the Respondent, or
if the Aggrieved Person does not request for conciliation, or if the conciliation process fails, and where the
Respondent is an Employee, the Internal Committee will proceed to make an inquiry into the complaint in
accordance with the provisions of this policy.

Process of Enquiry

After receiving a written complaint in the manner provided above, the Committee shall, within a period of 7 (seven)
working days from the date of receipt, send 1 (one) copy of the complaint to the Respondent. The Respondent shall be
given an opportunity to prepare a response to the complaint and submit to the Committee within a period of 10 (ten)
working days from the date of his receipt of the complaint and supporting documents.

The Complainant will be provided with a copy of the written explanation submitted by the Respondent.

If the Complainant or the Respondent desire to lead any evidence and/or require any wit-ness/es to be called, they shall
communicate in writing to the Committee, the names of such witness/es whom they propose to examine, after which
the Presiding Officer will summon the said witness(es).

If the Complainant or the Respondent desire to tender any documents by way of evidence before the Committee,
she/he shall supply true copies of such documents to the Committee as well as the other party.

All documents obtained in the enquiry process will be kept confidential.

If the Complainant or the Respondent desire to tender any documents by way of evidence before the Committee,
she/he shall supply true copies of such documents to the Committee as well as the other party.

The Committee should ensure that sufficient care is taken to avoid any retaliation against the witnesses. The meetings
of the Committee will be at such location as may be decided by the Committee keeping in view the need to maintain
confidentiality of the investigation. However, the convenience of the Complainant/Aggrieved Person will also be taken
into consideration. At all meetings of the Committee, a minimum of 3 (three) Investigating Members shall be present,
including the Presiding Officer.

During the process of inquiry, both the complainant and the accused would be expected to refrain from any form of
threat, intimidation or influencing of witnesses. So, that the Committee can conduct an impartial enquiry in accordance
with the principles of natural justice, i.e., the complainant and the witnesses will be offered to the accused for cross-

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examination and vice-versa and the Committee shall provide the Complainant and the Respondent and the relevant
witness, with the opportunity of being heard.

For the purpose of conducting and completing an inquiry, the Presiding Officer of the Committee may convene such
number of hearings as may be deemed necessary in order to dispose of the complaint. Notice of such hearings shall be
given to all persons who are required to be present, at least 3 (three) days before such hearing is scheduled to take
place. Both the Respondent and the Complainant (unless specifically exempted by the Internal Committee in writing)
shall be required to attend every hearing. If either party fails to attend 3 (three) consecutive hearings without sufficient
cause, the Internal Committee may terminate the inquiry or pass an ex-parte order. However, such an ex-parte
decision/recommendation may not be passed without giving a 15 (fifteen) day written notice in advance to the
concerned parties.

If the Committee so desires, both parties can be heard separately.

If the Complainant is a third party and does not agree for a personal appearance before the Committee due to any
reason, the Committee shall proceed with the inquiry on the basis of prima facie evidence.

The Committee shall record the entire process of hearing, and shall consider the minutes duly signed by the parties to
the inquiry, as token of their acceptance to the record.

If the Committee so desires, the Committee shall summon (by way of notice) any Employee, outsider or others to appear
before the Committee as a witness.

The Committee after careful examination, shall recommend to the Employer the disciplinary action which the
Committee thinks is fit for the Respondent.

The Committee will arrive at a decision after carefully and fairly reviewing the circumstances and evaluating the oral
and documentary evidence available on record (if any). The Committee is expected to complete the inquiry within a
period of 90 (ninety) days from the date of receipt of the complaint, and shall submit the inquiry report with its
recommendations to the Employer within 10 (ten) days of the closure of the inquiry and shall also make such report
available to the parties. The Employer is bound to act on such report within 60 (sixty) days of receipt.

During the inquiry procedure, none of the parties shall have a right to be represented by any legal practitioner.

The Aggrieved Person / Respondent shall have the right to appeal against the recommendations of the Internal
Committee, within a period of 90 (ninety) days.

Interim Measures

During the pendency of the inquiry, on a written request being made by the Aggrieved Person, the Internal Committee
may recommend that Smarsh: (i) transfers the Aggrieved Person to another office as deemed appropriate, or (ii)
transfers the Respondent to another office as deemed appropriate, or (iii) grant leave to the Aggrieved Person up to a
period of 3 (three) months, which shall be in addition to the leave the Aggrieved Person would be entitled to, or (iv)
restrain the Respondent from reporting on the work performance of the Aggrieved Person or writing appraisals/
confidential report(s). The Internal Committee may also recommend to Smarsh to suspend the Respondent with full
pay during the pendency of the inquiry if the circumstances so merit.

Internal Committee’s Recommendation

In the event the Respondent is found to be guilty of Sexual Harassment, depending upon the gravity of the offence and
without prejudice to any legal right(s) that the Aggrieved Person may have, the Internal Committee may make any of
the following recommendations of disciplinary action against the Respondent:

(i) Direct the Respondent to undergo training or counselling to address any specific issues;

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(ii) Direct the Respondent to provide a written apology to the Aggrieved Person clearly indicating that such behaviour
will not be repeated and that no retaliatory steps will be taken by him/her or others on his/her behalf against the
Aggrieved Person;
(iii) Transfer the Respondent to another position or to a different place;
(iv) Give a verbal or written warning which will also be noted in the Respondent's personnel record;
(v) Withhold increment or bonus (whether in full or part);
(vi) Withhold promotion;
(vii) Direct that the Respondent be terminated / suspended from employment; or
(viii) Any other recommendations as it may deem fit.

The Internal Committee may also recommend to Smarsh to deduct a sum from the salary of the Respondent and pay it
to the Aggrieved Person as compensation or direct the Respondent to pay a compensatory amount to the Aggrieved
Person. With respect to determining the amount of compensation, the Internal Committee shall have regard to: (i) the
mental trauma, pain suffering and distress caused to the Aggrieved Person, (ii) the loss of career opportunity, (iii)
medical expenses incurred for medical treatment, and (iv) income and financial status of the Respondent.

In the event the Internal Committee comes to the conclusion that the Respondent is not guilty, then the complaint shall
be dropped by the Committee and the Employer shall be notified that no further action need be taken.

If the Aggrieved Person desires to take criminal action against the Respondent, the Internal Committee and Smarsh shall
support the same, and also provide all reasonable assistance in this regard.

9. POLICY REVIEW & CHANGE AUTHORIZATION

Any change to the policy should be approved by the SVP &MD-India / HR.

10. PUNISHMENT FOR FALSE OR MALICIOUS COMPLAINT AND FALSE EVIDENCE

Where the Internal Committee arrives at a conclusion (after undertaking an inquiry) that the allegation against the
Respondent is malicious or that the Complainant has made the complaint knowing it to be false or that the Complainant
has produced any forged or misleading document, it may be recommended that Smarsh takes action against the
Complainant. The Internal Committee may also recommend that Smarsh takes appropriate disciplinary action, if it
arrives at a conclusion that any witness has given false evidence or produced any forged or misleading document. These
recommendations to be made by the Internal Committee will be similar to the recommendations of disciplinary action
that the Committee would make against the Respondent, should the allegation of Sexual Harassment be proved.
However, mere inability to substantiate a complaint or provide adequate proof will not result any action as detailed in
this clause.

11. CONFIDENTIALITY

Smarsh understands that it is difficult for the Complainant to come forward with a complaint of Sexual Harassment and
recognizes the Complainant's interest in keeping the matter confidential.

To protect the interests of the Complainant, the Internal Committee, Smarsh, the Complainant, Respondent, persons
assisting with the inquiry process and the witnesses will all be bound to keep information relating to the inquiry process
confidential, and shall not disclose the same to the general public / media.

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The Complainant, Respondent, witnesses, persons assisting with the inquiry process and Investigating Members (who are
Employees of Smarsh) would be liable for penalty 1 as may be determined by Smarsh, disciplinary action up to and including
termination, in case any of them breach the confidentiality of the inquiry process.

12. PROTECTION AGAINST RETALIATION

Smarsh prohibits any form of retaliation against anyone who has raised a complaint of Sexual Harassment or has co-operated
in any inquiry involving a complaint of Sexual Harassment.

Any individual who believes that he/she is experiencing retaliation, by way of intimidation, pressure to withdraw the case
or threats for reporting, testifying or otherwise participating in the proceedings, should report this to the Internal Committee
or the HR Department, and Smarsh will then address the concerns raised. Any person who is found to be guilty of retaliation
may be subject to appropriate disciplinary action. Anyone who abuses this procedure (for example, by maliciously making
an allegation knowing it to be untrue) would also be subject to disciplinary action.

13. ACCESS TO REPORTS AND DOCUMENTS

All records relating to Sexual Harassment complaints, including contents of meetings of the Internal Committee, results of
investigations and other relevant material will be kept confidential by Smarsh, except where disclosure is required under
disciplinary or other remedial processes and/or under applicable law.

14. DUTIES AND RESPONSIBILITIES OF THE EMPLOYER

Smarsh, as part of its obligations under the Act, shall be required to undertake the following actions:

i. Notifying, publishing and circulating notices stating that any and all acts of Sexual Harassment at the Workplace are
expressly prohibited;
ii. Providing appropriate and safe working conditions to the Employees in respect of work, leisure, health and hygiene,
including safety from all persons who enter the Workplace. If there is any indication that there may be a threat of
physical danger to any person, the Employer should seek professional advice in this regard;
iii. Helping to ensure that the Workplace environment is not hostile towards any Employee or that no Employee has
reasonable ground to believe that she/he was disadvantaged in that context;
iv. Displaying at a conspicuous place in the Workplace, the penal consequences for any act constituting Sexual
Harassment and the order constituting the Committee;
v. Declaring the name and contact details of the Internal Committee;
vi. Ensuring that staff and other Employees are aware of appropriate and acceptable standards of behavior;
vii. Making known this policy to all the Employees, including the procedure for making and addressing complaints;
viii. Taking early corrective action to deal with behavior that may constitute Sexual Harassment;
ix. Organizing workshops and awareness programs at regular intervals for sensitizing Employees;
x. Organizing seminars, orientation, capacity and skill building programs for the Investigating Members;
xi. If applicable, providing necessary facilities to the Committee for dealing with complaints and conducting the
inquiry, and generally ensuring that all allegations of Sexual Harassment are handled in a sensitive manner,
with respect to the dignity of the persons involved;
xii. Assisting in securing the attendance of the Respondent and the witnesses before the Committee;
xiii. Making available such information to the Committee as it may require with respect to the complaint;

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xiv. Providing assistance to the Aggrieved Person if she/he chooses to file a complaint in relation to the offence,
under the Indian Penal Code (“IPC”) or any other law for the time being in force;
xv. Initiating action under the IPC or any other law for the time being in force, against the perpetrator, or if the
Aggrieved Person so desires and where the perpetrator is an outsider, reporting the offence to the
jurisdictional police without loss of time;
xvi. Monitoring timely submission of reports by the Committee; and
xvii. Initiating disciplinary action against any Employee for breaching any provision(s) of this policy, which shall
include but not be limited to, termination of employment.

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Document ID: fbc0bbfbec9d79c11013e992a7bcd34242b3fa47

Requested:
Jun 18, 2024, 12:08 AM PDT (Jun 18, 2024, 7:08 AM UTC)
Kritika Dwivedi ([email protected])
IP: 27.4.55.124

Signed:
Jun 18, 2024, 12:41 AM PDT (Jun 18, 2024, 7:41 AM UTC)
Harsh Kumar ([email protected])
IP: 27.4.55.124

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