SEXUAL HARASSMENT POLICY

OBJECTIVES of a sexual nature. When any of these acts are

committed in circumstances where the victim of
such conduct has a reasonable apprehension that
1. The Company is committed to providing to all its in relation to the victim's employment or work, such
employees an environment free of gender based conduct can be humiliating or may constitute a
discrimination. In furtherance of this commitment, health and safety problem, it will amount to sexual
the Company strives to provide all its employees harassment. Sexual harassment includes, but will
with equal opportunity conditions of employment, not be confined to the following:
free from gender-based coercion, intimidation, or
exploitation. The Company is dedicated to ensure (a) Submission to unwelcome sexual advances,
enactment, observance and adherence of requests for sexual favours, and verbal or
guidelines and best practices that prevent and physical conduct of a sexual nature are made,
prosecute commission of acts of sexual either explicitly or implicitly, in return for a term
harassment. or condition of instruction, employment,
participation or evaluation of a person's
2. The Company believes that all individuals have the engagement in any Company activity;
right to be treated with dignity. Sexual harassment
(as defined in Section II below) by or towards any (b) When unwelcome sexual advances and verbal,
employee in the workplace will not be condoned. non-verbal, or physical conduct such as
sexually coloured remarks or jokes, letters,
3. This Policy applies to all allegations of sexual phone calls or e-mail, gestures, showing of
harassment made by any employee of the pornography or other visual displays of
Company against another employee irrespective of degrading sexual images, lurid stares, physical
whether sexual harassment is alleged to have contact or molestation, stalking, sounds of a
taken place within or outside Company premises. derogatory nature have the purpose or effect of
All actions prohibited by this Policy are also interfering with an individual's performance or
applicable to all individuals who are on Company of creating an intimidating, hostile or offensive
premises or on any other property where the environment;
Company conducts its business. If an individual
commits an act in violation of this Policy, whether (c) When any form of sexual assault is committed
an employee of the Company or a third party where a person uses the body or any part of it
interacting with the Company, the Company will or any object as an extension of the body in
take appropriate remedial measures under the relation to another person; and
circumstances, including measures to mitigate
against the potential for repetition, and to discipline (d) When any such conduct as defined in (a) and
any of its employees who may have participated in (b) above is committed by a third party or
such conduct, or may have failed to stop such outsider interacting with the Company in
conduct when he or she had the authority to do so. relation to an employee of the Company or vice
versa on the premises of the Company.

II. DEFINITIONS AND EXAMPLES OF 2. Sexual harassment may be of two kinds: hostile
work environment and an attitude of quid pro quo.
SEXUAL HARASSMENT (a) Hostile work environment constitutes sexual
harassment directed towards an individual
1. Sexual harassment includes any unwelcome, because of his or her gender and has the
sexually determined behaviour, direct or indirect, purpose or effect of (i) creating an intimidating,
physical contact and advances, a demand or hostile, or offensive work environment, or (ii)
request for sexual favours, sexually coloured unreasonably interfering with another's work
remarks, showing pornography, any other performance. Generally this includes
unwelcome physical, verbal or non verbal conduct

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 pornography in public places, foul language, own accord, to prevent and deal with sexual
etc and may not be directed at any individual harassment and to otherwise implement the Policy.
employee in particular, but the effect on all
employees is one of discomfort; 1. Composition: The Complaints Committee shall
consist of:
(b) Sexual harassment by one in a position of (a) one representative from the Legal Department;
power or influence constitutes quid pro quo (b) one representative from the Human Resource
sexual harassment when (i) submission by an Department;
individual is made either an explicit or implicit (c) one member from outside the Company (an
term or condition of employment, or (ii) NGO or, outside counsel or, a person or body
submission to or rejection of such conduct is conversant with dealing with the issue of sexual
used as the basis for employment decisions harassment), Subject always to at least half the
affecting that employee such as promotions, members of the Complaints Committee being
salary raises, etc. women and the Complaints Committee to be
headed by a woman member. Provided
III.OBLIGATIONS OF THE COMPANY however that a person shall cease to hold office
as a member of the Complaints Committee if
he/ she ceases to be an employee on account
1. The Company shall be responsible, among others, of resignation, termination, and death or for any
for the following: other reason whatsoever, and in such case the
(a) Prohibit, prevent and deter commission of acts Company shall fill the vacancy immediately.
of sexual harassment; 2. Disqualifications: A person shall be disqualified
(b) Implement the Policy by providing from being appointed, elected, nominated or
'discrimination and hostility free' work designated, or for continuing, as a member of the
environment; Complaints Committee, if there is any complaint
(c) Spread awareness of the Policy amongst its concerning sexual harassment pending against
employees, including by publication, notification him/her or if he/she is found guilty of sexual
and circulation of the Policy; harassment.
(d) Sensitizing employees about sexual 3. Confidentiality: To the fullest extent practicable and
harassment issues; consistent with the Complaints Committee's need
(e) Provide fair and impartial procedures for to investigate and ensure that corrective action is
resolution, settlement or prosecution of acts of taken, complaint of sexual harassment by
sexual harassment by taking all necessary employees will be processed confidentially.
steps, including those more particularly 4. Annual Report: The Complaints Committee shall
provided hereinafter; and make and submit an annual report on complaints
(f) Implementation of recommendations of the and action taken by it, in accordance with the
Complaints Committee (as hereinafter defined). Policy, to the appropriate Government authority.
2. The Company shall make an annual report in V. FILING A COMPLAINT
compliance with the Policy to the appropriate
Government authority. Any employee will have a right to lodge a complaint
3. Upon becoming aware of the commission of an concerning sexual harassment against an employee or
act(s) of sexual harassment, the Company shall a third party interacting with the Company
have the right to initiate action of its own accord, ("Complaint") with the Complaints Committee in terms
even in the absence of a formal complaint being of the Policy. The following steps will be followed in
filed by any employee. this regard:
(a) An employee making a Complaint ("Complainant")
will be afforded full confidentiality at this stage;
IV.COMPLAINTS COMMITTEE
(b) No person against whom a Complaint is made
A Complaints Committee will be set up by the shall be part of the Complaints Committee;
Company, which will deal with all cases of alleged
sexual harassment whether escalated to it by any (c) Within three (3) working days of the receipt of the
Company employee or taken up by the Company of its Complaint, the Complaints Committee will convene

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 a meeting of which advance written notice will be have the right to cross-examine witnesses
given to the Complainant; examined by the Complaints Committee;

(d) At this meeting, the Complainant will be entitled to (e) All the proceedings of the Complaints Committee
remain present personally; will be recorded and the same shall be made
available to the Complainant and the Accused;
(e) At the first meeting of the Complaints Committee,
the Complainant shall be heard and the Complaints (f) The Complaints Committee shall complete the
Committee shall decide whether the Complaint enquiry and make a report of its findings on the
should be proceeded with. The Complaint will be charges against the Accused and its decision to
dropped only if the Complainant on the face of it the management of the Company ("Management")
does not disclose an offence of sexual harassment; within a maximum period of sixty (60) days from
the date of filing of the Complaint by the
(f) In case the Complaints Committee decides to Complainant. The report of the Complaints
proceed with the Complaint, the wishes of the Committee shall also include recommendations to
Complainant concerning the issue shall be taken the Management for imposition of penalty and the
into account and if the Complainant so wishes the reasons for such recommendations.
accused ("Accused") will be called to a meeting of
the Complaints Committee, heard and if necessary, VII. IMPLEMENTATION OF RECOMMENDATIONS
warned about his or her behaviour and the matter
concluded with a recording to that effect made by
OF THE COMPLAINTS COMMITTEE
the Complaints Committee;
The Management shall consider the recommendations
and findings of the Complaints Committee and make a
(g) If the Complainant however, wishes to proceed
decision in relation to action to be taken against the
with the Complaint beyond a mere warning to the
Accused within ten (10) days of the submission of the
Accused, the same will be proceeded with in the
report by the Complaints Committee. The Management
manner prescribed in this Policy.
may issue such order and, or, directions as it deems
fit. The Management shall also endorse a copy of its
order to the Complainant, Accused and to the
VI. PROCEEDINGS OF THE COMPLAINTS Complaints Committee.
COMMITTEE
VIII. PUNISHMENT FOR SEXUAL HARASSMENT
(a) The Complaints Committee shall prepare the
statement of allegation and shall hand over the The Management can impose the following penalties
same to the Accused; on an employee held to be guilty of sexual
harassment. These penalties shall be classified as
(b) If the Accused desires to tender any written minor and major penalties:
explanation to the statement of allegation, he or
she shall submit the same to the Complaints (a) Minor penalties-
Committee; 1. warning
(b) Major penalties-
(c) The Complaints Committee shall give every 1. withholding of increment /promotion;
reasonable opportunity to the Complainant and the 2. reduction in Grade;
Accused, for putting forward and defending their 3. Termination of service.
respective case and to ensure that the
Complainant and Accused have full opportunity to Provided however, that in addition to these penalties,
present their claims, witnesses and evidence which the employee can also be required to give a written
may establish their claims; apology to the Complainant and upon his/her failure to
do so, the punishment can be enhanced.
(d) Both the Complainant and the Accused shall have
the right to submit supporting evidence and shall IX. PROTECTION AGAINST VICTIMISATION

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1. During the pendency of the Complaint, the 3. In the event, the Complaints Committee after
Company shall: investigation of a Complaint in accordance with the
procedure prescribed herein, concludes that the
(a) In the event the Accused is the Complainant's Complaint was false and made with malafide
Supervisor/Superior, review the possibility of intention by the Complainant, then the Complaints
relocating the Complainant within the Company Committee shall take such appropriate measures,
and ensure that the Complainant is not subject in consultation with the Management, against the
to appraisal by the Accused; Complainant, as it may deem necessary.

(b) Ensure that any sort of retaliation against the

Complainant or witnesses is strictly prohibited.
X. CRIMINAL PROCEEDINGS
Any act of reprisal, including internal
Where sexual harassment amounts to a specific
interference, coercion and restraint, by the
offence under the Indian Penal Code, 1860 or under
Accused, whether directly or indirectly, will
any other applicable law in India, the Management
result in appropriate action against the Accused
shall initiate appropriate action, in accordance with law
by the Complaints Committee in consultation
in India, by making a complaint with the appropriate
with the Management;
authority.
(c) Where the Accused is a third party interacting
with the Company, such Accused shall not be XI. MODIFICATION AND REVIEW OF THE
allowed to enter the Company premises except POLICY
for the purpose of attending the present
Complaint. The Company reserves the right to modify and, or,
review the provisions of this Policy, so as to comply
2. After the conclusion of the investigations of the with applicable legal requirements in India, internal
Complaint: policies, or with a view to fine tune or alter the
provisions of this Policy to the extent deemed
(a) If the Accused is found to be guilty, the necessary by the Company from time to time.
Accused shall not write the Appraisal Reports
of the Complainant, if he or she is otherwise so
authorized;

(b) Where the Accused is a third party interacting

with the Company, and found to be guilty, the
Accused shall not be allowed to enter the
Company premises.