1. Introduction
2. Scope
This policy applies to all employees, including permanent, temporary, contract, and outsourced staff, as well as visitors, vendors, and clients who interact with Company personnel at any location associated with work. It is applicable to all work-related interactions, including those occurring during business trips, company-sponsored events, conferences, and online communications. The policy covers both physical office premises and virtual workspaces, ensuring a safe and harassment-free professional environment.
3. Definition of Sexual Harassment
Sexual harassment includes, but is not limited to:
| Category | Examples |
|---|---|
| Physical Harassment | Unwelcome physical contact and advances, inappropriate touching, blocking movement, or any physical interference that is unwarranted and offensive. |
| Verbal Harassment | Sexually suggestive comments, offensive jokes, derogatory remarks about gender or sexuality, repeated and unwelcome romantic advances. |
| Visual Harassment | Showing pornography, displaying sexually explicit images, sending inappropriate messages, lewd gestures, or suggestive expressions. |
| Non-Verbal Harassment | Staring, suggestive body language, whistling, or any behavior that creates a hostile work environment. |
4. Internal Complaints Committee (ICC)
The Company has constituted an Internal Complaints Committee (ICC) to address sexual harassment complaints. The ICC is responsible for ensuring a fair and unbiased inquiry process and taking appropriate action against offenders. The ICC consists of:
| Designation | Role | Name | Contact |
|---|---|---|---|
| Presiding Officer | Senior male employee with relevant experience in gender sensitivity and workplace safety. | ||
| Employee Representatives | Two or more members from different departments to ensure diverse representation. | ||
| External Member | An NGO or legal expert with experience in handling sexual harassment cases to provide an objective perspective. |
The ICC is mandated to function independently and fairly, ensuring that complaints are handled with strict confidentiality and professionalism.
5. Complaint Filing Process
• Any aggrieved person may submit a written complaint to the ICC within three months of the incident.
• Complaints may be submitted via email, in writing to the ICC’s designated address, or through an anonymous complaint mechanism where applicable.
• The ICC may extend the filing period in exceptional cases where the complainant was unable to file due to compelling circumstances.
• Employees are encouraged to report incidents immediately, ensuring timely intervention and action.
Complaint Handling Steps:
1. Incident Occurs
2. Complaint Submitted to ICC
3. ICC Acknowledges Complaint
4. Inquiry Initiated
5. Hearing of Both Parties
6. Investigation & Report Submission
7. Management Decision & Action Taken
6. Inquiry Process
• The ICC will conduct a fair, unbiased, and confidential inquiry within 90 days of receiving the complaint.
• Both parties will be given an opportunity to present their case, including witnesses and supporting evidence.
• The ICC may seek external expertise in complex cases to ensure thorough and impartial handling.
• A report will be submitted to the management with recommendations for corrective measures or disciplinary action.
• The Company shall implement the ICC’s recommendations within 60 days to ensure compliance and maintain a safe work environment.
7. Disciplinary Action
Disciplinary actions for those found guilty of sexual harassment will be proportionate to the severity of the offense. These may include:
| Severity | Action |
|---|---|
| Minor Violation | Verbal or written warning, mandatory counseling, sensitivity training. |
| Moderate Violation | Transfer to another department, deduction in benefits, probationary period with behavioral monitoring. |
| Severe Violation | Suspension, termination, legal action, reporting to law enforcement authorities if necessary. |
The Company maintains a strict stance against false or malicious complaints. If a complaint is found to be false with intent to defame, the complainant may also be subjected to disciplinary action as per the Company’s policies.
8. Confidentiality
• The identity of the complainant, respondent, and witnesses shall be kept strictly confidential.
• Any breach of confidentiality by any party involved in the inquiry process will lead to disciplinary action.
• The ICC will maintain all complaint records securely and will not disclose details unless required by law or authorized personnel.
• Employees are encouraged to report concerns without fear of retaliation, as the Company ensures protection against victimization of complainants and witnesses.
9. Awareness & Training
To ensure effective implementation of this policy, the Company will conduct periodic training and awareness programs:
| Training Program | Frequency |
|---|---|
| Employee Awareness Session | Annually, with refresher sessions as needed. |
| ICC Training | Every six months to keep the committee updated on best practices and legal guidelines. |
| POSH Policy Refresh | Conducted as needed, especially after policy updates or legal amendments. |
All employees are required to participate in these training programs to understand their rights and responsibilities under this policy.
10. Conclusion
Palmary Projects & Services Private Limited maintains a zero-tolerance policy towards sexual harassment. Employees are encouraged to report incidents without fear of retaliation. The Company is committed to fostering a respectful, safe, and inclusive workplace culture where all individuals can work with dignity and security.
For any queries or complaints, please contact: [hr@.com]
This policy is effective from [01-01-2022] and is subject to periodic review to ensure compliance with evolving legal and organizational requirements.
