1.1 This POSH Policy is established in compliance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (hereinafter referred to as 'the Act'), and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013 (hereinafter referred to as 'the Rules'), to provide a safe, secure, and harassment-free working environment for all employees, with particular emphasis on the protection of women employees as mandated by the Act. The Organization is committed to upholding the spirit and letter of the Act and recognises that sexual harassment constitutes a violation of the fundamental right to equality and dignity under Articles 14, 15, and 21 of the Constitution of India.

1.2 This policy applies to all employees of the Organization, including regular, temporary, contractual, probationary, trainee, and apprentice employees, regardless of gender, in so far as they may be respondents to a complaint. In accordance with the Act, an 'aggrieved woman' includes any woman employee as well as any woman who visits the workplace in connection with work, including clients, customers, vendors, interns, and domestic workers. The 'workplace' as defined under the Act includes the Organization's registered offices, branch offices, factories, project sites, and any place visited by an employee arising out of or during the course of employment, including transportation provided by the Organization, client premises, off-site meetings, conferences, and work-related social events.

1.3 The Organization shall constitute an Internal Complaints Committee (ICC) at each workplace or administrative unit employing 10 or more employees, in compliance with Section 4 of the Act. The ICC shall comprise a Presiding Officer, who shall be a senior woman employee at the workplace; not less than two members from amongst employees who are committed to the cause of women or have experience in social work or legal knowledge; and one external member from a non-governmental organization or association committed to the cause of women, or a person familiar with issues relating to sexual harassment, as mandated by the Act. At least one-half of the ICC members shall be women. The ICC members shall be appointed for a term of three years and shall not hold office for more than two consecutive terms. The Organization shall ensure that ICC members receive adequate training on the provisions of the Act, investigation methodology, and the principles of natural justice.

2.1 In accordance with Section 2(n) of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, sexual harassment includes any one or more of the following unwelcome acts or behavior, whether directly or by implication: physical contact and advances; a demand or request for sexual favours; making sexually colored remarks; showing pornography; and any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature. The following circumstances, among others, if they occur or are present in relation to or connected with any act or behavior of sexual harassment, may amount to sexual harassment: implied or explicit promise of preferential treatment in employment; implied or explicit threat of detrimental treatment in employment; implied or explicit threat about the present or future employment status; interference with work or creation of an intimidating, offensive, or hostile work environment; and humiliating treatment likely to affect health or safety.

2.2 Sexual harassment may be perpetrated by any individual against any other individual, regardless of gender, hierarchical position, or employment status, and may occur between colleagues, between a supervisor and subordinate, between an employee and a client or vendor, or between any other individuals in the workplace context. Sexual harassment may take the form of quid pro quo harassment, where submission to or rejection of unwelcome sexual conduct is made, explicitly or implicitly, a term or condition of employment, a basis for employment decisions, or is used to interfere with the individual's work performance; or hostile work environment harassment, where unwelcome sexual conduct is sufficiently severe, pervasive, or persistent to alter the conditions of the individual's employment and create an abusive, intimidating, or offensive working environment, even in the absence of any economic or employment consequence.

2.3 Examples of conduct that may constitute sexual harassment include, but are not limited to: unwanted physical contact such as touching, patting, brushing against, or cornering; sexual propositions, innuendos, or suggestive comments; sexual jokes, stories, or language in conversation or communication; display, circulation, or sharing of sexually explicit or suggestive images, videos, objects, or written material, whether physical or electronic; leering, whistling, or making sexually suggestive gestures; stalking or cyberstalking, including persistent monitoring, following, or sending unwanted communications; repeatedly requesting dates or social engagements after being declined; intrusive questions about an individual's sexual life, body, or appearance; and any act of retaliation against an individual who has refused sexual advances or has reported sexual harassment.

3.1 In accordance with Section 9 of the Act, an aggrieved woman may file a written complaint of sexual harassment with the Internal Complaints Committee within a period of three months from the date of the incident, or in the case of a series of incidents, within a period of three months from the date of the last incident. The ICC may, for reasons to be recorded in writing, extend the time limit by a further period of up to three months if it is satisfied that the circumstances were such that prevented the woman from filing the complaint within the prescribed period. Where the aggrieved woman is unable to make a written complaint on account of physical or mental incapacity or death, a complaint may be filed by her legal heir, relative, friend, co-worker, officer of the National Commission for Women or State Women's Commission, or any person who has knowledge of the incident, with the written consent of the aggrieved woman where she is alive and capable of giving consent.

3.2 In accordance with Section 10 of the Act, upon receiving a complaint, the ICC shall, before initiating an inquiry and at the written request of the aggrieved woman, take steps to settle the matter between the aggrieved woman and the respondent through conciliation. Conciliation shall not be imposed upon the aggrieved woman and shall only be attempted if she expressly requests it. No monetary settlement shall be made the basis of conciliation. If a settlement is arrived at, the ICC shall record the settlement and forward copies to the aggrieved woman and the respondent. If the terms of the settlement are not complied with by the respondent, the ICC shall proceed to conduct an inquiry into the complaint. Where no settlement is reached, or where the aggrieved woman does not request conciliation, the ICC shall proceed to inquire into the complaint in accordance with the provisions of the Act.

3.3 In accordance with Section 11 of the Act, the ICC shall conduct an inquiry into the complaint in a manner consistent with the principles of natural justice, affording both the aggrieved woman and the respondent a reasonable opportunity to present their case, produce evidence, and cross-examine witnesses. The ICC may request the Organization to grant the aggrieved woman, during the pendency of the inquiry, leave of absence, transfer to another workplace, or any other interim relief as it deems fit. The inquiry shall be completed within a period of 90 days from the date of filing of the complaint. Upon completion of the inquiry, the ICC shall provide a report of its findings to the employer, or the District Officer as the case may be, within 10 days of completion of the inquiry, along with its recommendations regarding the action to be taken.

3.4 In accordance with Section 12 of the Act, during the pendency of the inquiry, the ICC may, on a written request by the aggrieved woman, recommend to the employer interim measures including the transfer of the aggrieved woman or the respondent to another workplace; the grant of leave to the aggrieved woman up to a period of three months, which shall be in addition to her regular leave entitlement; restraining the respondent from reporting on or supervising the work performance of the aggrieved woman, or from writing her confidential report; and any other relief as the ICC deems appropriate to prevent recurrence of the harassment or to protect the aggrieved woman from a hostile work environment during the inquiry period. The employer shall implement the ICC's interim recommendations and shall report compliance to the ICC.

4.1 In accordance with Section 13 of the Act, where the ICC concludes that the allegation against the respondent has been proved, it shall recommend to the employer to take action for sexual harassment as misconduct in accordance with the provisions of the Organization's service rules. Recommended actions may include a written apology, formal written warning, withholding of promotion or increment for a specified period, termination of employment, mandatory counselling, community service, or any other action that the ICC deems appropriate having regard to the severity and circumstances of the harassment. The employer shall act upon the ICC's recommendation within 60 days of receipt of the inquiry report. The ICC may also recommend the deduction from the respondent's salary of such compensation as it may determine, to be paid to the aggrieved woman for the distress, loss, and damage suffered.

4.2 The Organization shall provide a copy of the ICC's findings and recommendations to both the aggrieved woman and the respondent within the prescribed timeline. Both parties shall be informed of their right to appeal the findings or recommendations to the court or tribunal of competent jurisdiction, in accordance with Section 18 of the Act, within 90 days of the date of the recommendation. The Organization shall cooperate fully with any appellate proceedings and shall implement the final order of the court or tribunal. Where the ICC finds that the allegation is not proved, no action shall be taken against the aggrieved woman for having filed the complaint, unless the ICC determines that the complaint was made with malicious intent or was false or frivolous, in which case the ICC may recommend action against the complainant in accordance with the Organization's service rules.

4.3 In compliance with Section 21 of the Act, the Organization shall include in its annual report, or where no annual report is required, shall file separately with the District Officer, information regarding the number of cases filed with the ICC during the year, the number of cases disposed of during the year, the number of cases pending for more than 90 days, the nature of action taken by the employer on the recommendations of the ICC, and the number of workshops or awareness programs conducted for employees. The Organization shall maintain accurate records of all complaints, inquiries, and outcomes for a minimum period of 7 years, or such longer period as may be required by law. The ICC shall submit a quarterly summary report to the management on the status of complaints and the Organization's overall POSH compliance posture.

5.1 In compliance with Section 19 of the Act, the Organization shall organise mandatory awareness workshops and training programs on the prevention of sexual harassment for all employees at least once annually, and for all new employees as part of the onboarding process. Training shall cover the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, the definition and examples of sexual harassment, the Organization's complaint filing process and ICC contact details, the rights of the aggrieved woman and the respondent, the consequences of engaging in sexual harassment and of filing false or malicious complaints, and bystander intervention strategies. The Organization shall display conspicuously at the workplace the penal consequences of sexual harassment, the order constituting the ICC, and the complaint filing process, in accordance with Section 19 of the Act.

5.2 In accordance with Section 19 of the Act, the Organization shall take the following steps to prevent sexual harassment and to create a safe and supportive working environment: provide a safe working environment that is free from hostility and conducive to respectful professional interactions; display at conspicuous places in the workplace the penal consequences of sexual harassment and the constitution and contact details of the ICC; include the provisions of this policy and the Act in the Organization's service rules and employee handbook; treat sexual harassment as serious misconduct under its service rules; ensure that ICC members and all relevant personnel receive adequate training on the Act and on investigation methodology; provide necessary facilities to the ICC for conducting inquiries; assist in securing the attendance of the respondent and witnesses before the ICC; and make available information relating to the complaint to the aggrieved woman and the respondent. The Organization shall review and update its prevention measures annually based on ICC data and employee feedback.

5.3 This policy shall be reviewed comprehensively at least once every 12 months by the policy owner in consultation with the ICC, Legal Counsel, and the HR department, to ensure continued compliance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, and the Rules framed thereunder. Any amendments to the Act, the Rules, or relevant judicial pronouncements that affect the Organization's obligations shall be incorporated into this policy within 30 calendar days of their notification or publication. The policy shall be made available to all employees in the languages commonly understood by the workforce and shall be accessible on the Organization's intranet and in printed form at each workplace. The Organization shall seek legal advice at least annually to ensure that its POSH framework remains legally robust and aligned with evolving jurisprudence.