POLICY ON PREVENTION OF SEXUAL HARASSMENT (POSH) AT WORKPLACE
To create and maintain safe work environment, free form sexual harassment & discrimination for all employees, as per the guidelines of “The Sexual harassment of women at workplace (prevention, prohibition & redressal) Act, 2013.
Navriti is committed to providing a safe environment for all its employees free from discrimination on any ground and from harassment at work including sexual harassment. Navriti will operate a zero tolerance policy for any form of sexual harassment in the workplace, treat all incidents seriously and promptly investigate all allegations of sexual harassment. Any person found to have sexually harassed another will face disciplinary action, up to and including dismissal from employment. All complaints of sexual harassment will be taken seriously and treated with respect and in confidence. No one will be victimised for making such a complaint.
Navriti is committed to providing a work environment that ensures every employee is treated with dignity and respect and afforded equitable treatment. Navriti is also committed to promoting a work environment that is conducive to the professional growth of its employees and encourages equality of opportunity. The Company will not tolerate any form of sexual harassment and is committed to take all necessary steps to ensure that its employees are not subjected to any form of harassment.
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 suppliers or any other business associates.
The workplace includes:
DEFINITION OF TERMS:
RESPONSIBILITIES REGARDING SEXUAL HARASSMENT:
III. Provide assistance to complainant: Employer shall offer Assistance to the complainant if he/she so chooses to file a complaint in relation to the offence under the Indian Penal Code (IPC) or any other law.
III. ICC may at periodic intervals formulate programs for creating awareness of the policy amongst the employer and employees of the organization.
VII. ICC shall ensure and supervise proper constitution and functioning of the Sub-Committee for investigation of complaints.
VIII. ICC shall take into consideration and discuss on each and every instance of sexual harassment that the organization may have come across, including during exit interviews, gossips, rumors.
In accordance with the provisions of “The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013”, the management of the company is pleased to constitute an Internal Complaints Committee named as “Complaints Committee” as under to prevent the cases of sexual harassment and to provide mechanism for the resolution of complaints of sexual harassment within fixed time limit of such complaints at the work place at Navriti Technologies Pvt. Ltd.
Initially, and till further notice, the Complaints Committee will comprise of the following 5 members:
The Presiding Officer reserves the right to nominate more members of appropriate seniority and rank in the committee to conduct such enquiries to ensure equal representation of the gender as that of the complainant or for any other valid reason.
The Complaints Committee is responsible for:
Current nominated members of the committees are given in Annexure: A. The tenure of the members of the Committee is for three years from 1st December 2018.
III. ICC will thereafter provide advice or extend support as requested and will undertake prompt investigation to resolve the matter.
A complaint shall be submitted in writing (either email or sealed envelope) to any member of the Internal Committee mentioned herein within 3 months of occurrence of an act of Sexual Harassment along with supporting documents if any, and the names and addresses of the witnesses. The complainant is required to disclose the following to enable the Presiding Officer to contact him/her and take the matter forward:
If the respondent is the direct supervisor of the complainant, or person influencing the career growth of the complainant, the reporting structure will be changed till the time the enquiry is completed.
If the aggrieved person is unable to lodge the complaint on account of his/her incapacity, the following may do so on his/her behalf, with his/her written consent.
Legal heir, relative or friend
Any person having the knowledge of the incident
Once the complaint is received, before initiating the inquiry, the committee may take steps to conciliate the complaint between the complainant and the respondent. This is only if requested by the aggrieved person.
It is made clear to all parties that conciliation in itself doesn’t necessarily mean acceptance of complaint by the respondent. It is a practical mechanism through which issues are resolved or misunderstandings cleared. In case a settlement is arrived at, the committee records & reports the same to the employer for taking appropriate action. Resolution through conciliation happens within 2 weeks of receipt of complaint. The committee provides copies of the settlement to the complainant & respondent. Once the action is implemented, no further inquiry is conducted.
FINDINGS OF COMPLAINTS COMMITTEE:
When the committee arrives at the conclusion that the allegation against the respondent has not been proved, it recommends to the employer that no action is required to be taken in this matter.
Further, the committee ensures that both parties understand that the matter has been fully investigated, that the matter is now concluded and neither will be disadvantaged within the company.
Where the committee arrives at the conclusion that the allegation against the respondent has been proved, it recommends to the employer to take necessary action for sexual harassment as misconduct, in accordance with the applicable service rules and policies, and this may include:
III. Apology to be tendered by respondent
VIII. Or any other action that the Management may deem fit.
The employer at Navriti Technologies Pvt. Ltd. acts upon the recommendations within 60 days and confirms to the committee.
Post implementation of the actions, follow up with the complainant occurs to ascertain whether the behaviour has in fact stopped, the solution is working satisfactorily and if no victimization of either party is occurring. This follow up is undertaken by the complainant’s Line Manager supported by HR.
Where the committee arrives at the conclusion that the allegation against the respondent is malicious or the aggrieved woman or any other person making the complaint has made the complaint knowing it to be false or the aggrieved woman or any other person making the complaint has produced any forged or misleading document, it may recommend to the employer to take action against the woman or the person making the complaint.
The action recommended should be similar to the ones proposed for the respondent in case of substantiated complaints.
While deciding malicious intent, the committee should consider that mere inability to substantiate a complaint need not mean malicious intent. Malicious intent must be clearly established through a separate inquiry
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.
ACCESS TO 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.
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.
REVISIONS TO THE POLICY:
The Employer/ICC may review or modify this Policy, if so required, in order to make the enforcement of the Policy more expedient or to accommodate any changes in the law.
In conclusion, the Organization reiterates its commitment to providing all its employees, a workplace free from harassment/ discrimination and where every employee is treated with dignity and respect.
COMPLAINT COMMITTEE (CC):
The following members are nominated to constitute a Complaint Committee for Navriti Technologies. This Complaint Committee is effective from 1st December 2018.
The tenure of the members of the committee is for three years from 1st December 2018. The Employer shall reconstitute the committee after 3 years from the date of formation of CC. In the event vacancy arises due to resignation, voluntary withdrawal or otherwise by any member of CC before the expiry of tenure, Employer shall exercise its right to reconstitute the committee within (15) fifteen working days from the date when such a vacancy arises.
Name of the Committee Member
Manager – HR
Poornima H D
Senior Executive- Back Office
Manager – Content
Assistant General Manager – Delivery
Maria F Madtha
External Member- NGO
External Member- NGO