Playo - Prevention, Prohibition and Redressal Policy on Sexual Harassment of Women at Workplace
I. PURPOSE
TechMash (“Company”) strives to create and maintain a healthy, safe and productive work environment, free from discrimination and harassment. The Company is committed to maintaining a positive, safe and productive working environment for all its employees at their workplaces, that enables them to work without fear of prejudice, gender bias and sexual harassment of any form and manner. Accordingly, this Policy on Sexual Harassment Free workplace (Prevention, Prohibition and Redressal) ("Policy") has been framed with the intention of providing a sexual harassment free environment and addresses the prevention and redressal of sexual harassment at the workplace for all employees of the Company in India.
At TechMash, we have zero-tolerance for sexual harassment. The purpose of the Policy is to promote a work place free from sexual harassment, prevent and minimize harassment of sexual nature, and provide an appropriate mechanism to redress the complaints and ensure time bound redressal and to promote a healthy work environment.
This Policy has been framed in accordance with the provisions of The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and Rules framed thereunder (hereinafter referred to as “POSH Act” and “POSH Rules” respectively) in 2013, applicable throughout India.. Commission of any act of sexual harassment as defined in the Act and in this Policy shall result in strict disciplinary action. Accordingly, while the policy covers all the key aspects of the Act, for any further clarification reference shall always be made to the Act and the provisions of the Act shall prevail.
The Company is committed to provide redressal against sexual harassment to all women employees and associated stakeholders as applicable under the definition of “Employees” and “Aggrieved/Complainant”, and to take strict disciplinary action as provided under this Policy against any persons who are perpetrators of any and all forms of sexual harassment.
II. SCOPE
This Policy addresses the prevention and redressal of sexual harassment at the workplace (as defined in the further section), and is applicable to all employees associated with the Company’s operations in India.
Also, while this Policy covers all the key aspects of the POSH Act, reference shall always be made to the POSH Act for any further clarification and the provisions of the POSH Act shall prevail in case of any discrepancy.
III. DEFINITIONS
Aggrieved Individual or Complainant, in relation to a workplace, is a woman, of any age, whether an Employee or not, who alleges to have been subjected to any act of sexual harassment.
Respondent refers to a person against whom a complaint of sexual harassment has been made by the Aggrieved/Complainant.
Employee for the purpose of this Policy person employed at the workplace, for any work on regular, temporary, ad-hoc or daily wage basis, either directly or through an agent, including a contractor, with or without the knowledge of the principal employer, whether for remuneration or not, or working on a voluntary basis or otherwise, whether the terms of employment are express or implied and includes a coworker, a contract worker, probationer, trainee, apprentice or by any other such name.
Workplace for the purpose of this Policy includes the premises and offices of the Company, its affiliates and any place visited by Employees arising out of or during employment including transportation provided by the Company for undertaking such journey. Additionally, any individual representing the Company in the capacity of an “Employee”, anywhere in India or outside, in existing and potential official engagements, out station travels and conferences, training and capacity building programs, including Company engagements, Company gatherings and parties, will be considered engaging in extended workplaces of the Company. Also, all official platforms of communication, including but not limited to emails, official discussion forums, official Whatsapp group/s, official telephone conversations with internal or external stakeholders of the Company will be considered as “workplace” for all Employees and the guidelines of this Policy will extend to them as well.
Employer for the purpose of the Act refers to any person or board or committee responsible for management, supervision and control of the workplace, including formulation and administration of policies of the Company.
Internal Complaints Committee (“ICC”) refers to the internal redressal committee established with the Company to receive and inquire complaints pertaining to sexual harassment at workplace incidents and provide its final recommendations to the employer, i.e. management of the Company for implementation. You can find the find the details of the current ICC members across all locations of the Company in Annexure A of this Policy.
Witness for the purpose of this Policy refers to any individual, from within, or outside the organization who has been mentioned in the narration of the Complainant or Respondent to be called upon as a validator on their part, or has been identified as a similar contributor by the ICC on its own.
Management for the purpose of this Policy means Company’s Officer or Officers/ Nominee or Nominees as may be authorized in this behalf by the Promoter/Managing Director/ Director who will be responsible for implementing the recommendations of the ICC within the Company.
IV. ACTIONS DEFINED AND IDENTIFIED AS SEXUAL HARASSMENT AT WORKPLACE
Sexual harassment: “Sexual Harassment” includes any one or more of the following unwelcome acts or behavior (whether directly or by implication) that would cause discomfort and/or humiliate a person at whom the behavior or conduct was directed namely:
Deliberate Physical contact and advances
Unnecessary or unwanted bodily contact such as groping or massaging.
Demand or request for sexual favors;
Unwelcome sexual attention or invitations
Use of abusive language or any other foul language which shows disrespect towards women.
Sexually colored remarks or remarks of a sexual nature about a person's clothing or body;
Showing pornography, making or posting sexual pranks, sexual teasing, sexual jokes, sexually demeaning or offensive pictures, cartoons or other materials through email, SMS, MMS etc.;
Repeatedly asking to socialize during off-duty hours or continued expressions of sexual interest against a person’s wishes;
Giving gifts or leaving objects that are sexually suggestive;
Eve teasing, innuendos and taunts, physical confinement against one’s will or any such act likely to intrude upon one’s privacy;
Persistent watching, following, contacting of a person; and any other unwelcome physical, verbal or non-verbal conduct of sexual nature.
Non-verbal behavior such as staring, leering, or gestures;
Sexual Innuendos or veiled threats;
Displaying or sharing offensive images such as posters, videos, photos, cartoons, screensavers, emails, or drawings that are derogatory or sexual;
The following circumstances if it occurs or is present in relation to any sexually determined act or behavior 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;
Sexual harassment, which is harassment specifically based on sex, can take two forms:
Hostile Work Environment: Conduct that has the purpose or effect of unreasonably interfering with an employee's work performance or creating an intimidating, hostile, or offensive working environment; and
Quid Pro Quo Harassment: Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when submission to such conduct is made either explicitly or implicitly a term or condition of an employee's employment, or when submission to or rejection of such conduct by an employee is used as the basis for employment decisions affecting that employee.
Important Pointers:
The list & details given below are not exhaustive. While it is not possible to list all those additional circumstances that may constitute sexual harassment, there could be some instances of conduct which if unwelcome, may constitute sexual harassment depending upon the totality of the circumstances including the severity of the conduct and its pervasiveness.
It is the reasonable perception of the aggrieved individual that would be relevant in determining:
whether the conduct was sexual in nature, and, if so, whether such conduct was unwelcome or not; and/or
that their objection to such conduct would disadvantage them in connection with their employment including [hiring, dismissal, performance appraisal, promotion/demotion, assignments, monetary appraisal] evaluation, grading, recruitment or promotion; or
if the conduct in question creates a hostile working environment.
Sexual Harassment may occur not only where a person uses sexual behavior to control, influence or affect the career, salary or job of another person, but also between co-workers, it may also occur between a Josh Talks employee and someone that employee deals with in the course of his/her work who is not employed by the Company. Sexual harassment can happen regardless of the individuals’ gender, gender identity, or gender expression and can, for example, occur between same-sex individuals as well as between opposite-sex individuals, and does not require that the harassing conduct be motivated by sexual desire.
All the above is prohibited through any mode of communication including in person, over the phone, on voice mail, through pen and paper, on e-mail, through chat, through SMS or any other form of communication.
Sexual harassment does not refer to occasional compliments of a socially acceptable nature. It refers instead to unwelcome sexually determined behavior, or pattern of conduct, that would cause discomfort and/or humiliate a woman at whom the behavior or conduct was directed.
V. ROLES AND RESPONSIBILITIES OF COMPANY’S STAKEHOLDERS
Responsibilities of the Management of the Company: The Management of the Company must ensure the following for the Company:
Encourage respectful and dignified behaviour at workplace at all times by all Employees;
Have zero tolerance towards acts of sexual harassment at workplace;
Ensure a safe working environment, free from any kind of sexual harassment including implementing an active program for prevention and deterrence of sexual harassment;
To provide guidelines for redressal against any act of sexual harassment in the workplace.
As mandated by the POSH Act, the role of the Management of the Company also extends to the following activities:
Treat sexual harassment as misconduct under the service rules and take appropriate action for the same;
Maintain a proactive program to educate all Employees about the definition of sexual harassment at workplace and procedure for redressal;
Prominently display notices in various places in the establishment, spreading awareness about the issue of prevention of sexual harassment at workplace and giving information about the redressal mechanism that has been put in place;
Provide assistance to the aggrieved individual who is a woman, if she chooses to file a complaint in relation to the offence of sexual harassment at workplace under the Indian Penal Code (IPC) or any other applicable law.
Cause to initiate action, if the aggrieved individual who is a woman so desires, against the perpetrator for the offence of sexual harassment at workplace under IPC or any other applicable law if the perpetrator is not an Employee of the workplace at which the incident of sexual harassment took place.
Educate the team that the Company has a zero tolerance towards sexual harassment at workplace and any such misconduct will be directly reported to the ICC established within the Company;
Ensure that all complaints pertaining to sexual harassment at workplace, if brought to their attention by an Employee, are immediately communicated to the relevant ICC;
Ensure that any written or oral complaints pertaining to sexual harassment at workplace received by them from their subordinate(s) are immediately (within 24 hours) forwarded to the relevant ICC;
Ensure the Complainant(s) that such complaints will be taken seriously by ICC and will be inquired as per this Policy and provisions of the law;
Ensure the Complainant(s) that they would not face retaliation of any kind of reporting such incidents to the ICC;
Ensure the Complainant/ Respondent/s, or witnesses that they would not face any undue victimization within the Company.
Maintain the confidentiality of all information disclosed as to any incident of sexual harassment and in the course of the relevant investigations (in instances where the such manager and team leader is made aware of any details of an on-going investigation and in instances where the aggrieved person approaches their manager or team leader directly with a complaint).
Responsibilities of the Employees: At the Company, all Employees are expected to uphold the highest standards of ethical conduct at the workplace and in all their interactions with business stakeholders. The Employees have a responsibility to:
Treat each other with respect;
Follow the letter and spirit of law;
Refrain from any unwelcome behavior that has a sexual connotation (of sexual nature);
Refrain from creating hostile environment at workplace via sexual harassment; and
Refusing to participate in any activity which constitutes sexual harassment;
Supporting their colleagues at the Company to reject unwelcome sexual behaviour;
Report sexual harassment experienced to ICC immediately and abide by the complaint handling procedure of the Company.
Act as a witness if the person being harassed decides to lodge a complaint to the ICC of the Company.
All are encouraged to advise others of behaviour that is unwelcome. Often, some behaviour is not intentional. While this does not make it acceptable, it does give the person behaving inappropriately, the opportunity to modify or stop their offensive behaviour.
VI. Internal Complaints Committee (ICC)
As mandated by the POSH Act, the Company has constituted a committee to be known as the Internal Complaints Committee (“ICC”) in any or each of its offices with 10 or more Employees to address and redress complaints of sexual harassment. As per the POSH Act, the ICC shall comprise of:
A Presiding Officer (“Presiding Officer”), who shall be a woman Employee at a senior level in the Company; not less than two Members (“Members”) from amongst Employees preferably committed to or who have had experience in social work or have legal knowledge; one member (“External member”) from amongst non-government organizations or associations committed to the cause of women or a person familiar with the issues relating to sexual harassment;
At least one half (50%) of the total members so nominated shall be women.
The Company has extended the availability of the ICC to receive complaints of all Employees, irrespective of their gender. The nomination of ICC members will be made by the Management of the Company and reviewed from time to time. Additional members will also be added as may be required from time to time. You can find the find the details of the current ICC members across all locations of the Company in Annexure A of this Policy.
The email ID of the ICC is icc@playo.co
This email ID shall be used by any Complainant to send their complaint of sexual harassment at workplace to the ICC.
The ICC as the redressal committee is responsible for:
Receiving complaints of sexual harassment at the workplace;
Initiating and conducting inquiry as per the established procedure under law;
Submitting findings and final recommendations on complaints of sexual harassment at workplace which will be implemented by the Company;
Maintaining strict confidentiality throughout the process as per established guidelines; and
Ensuring absolute transparency in its activities, disclosing necessary information to the respective stakeholders when required and investigating the complaints while abiding by the principles of natural justice.
VII. FILING A COMPLAINT OF SEXUAL HARASSMENT AT WORKPLACE
Filing a complaint
Timeline: Any Aggrieved Individual who has experienced or has been subjected to any act of sexual harassment by an Employee shall be entitled to lodge a complaint in writing with the ICC. The complaint shall be lodged within three (3) months from the date of the alleged incident of sexual harassment and in case of a series of incidents, within a period of three (3) months from the date of the last incident.
Discretion of the ICC to extend timeline: If there is a delay beyond three (3) months, the ICC may extend the time limit by another three (3) months, on being satisfied about the circumstances that prevented the Complainant from filing a complaint within the prescribed period.
Only written complaint accepted by ICC: The ICC can initiate inquiry on the complaint only if the complaint is in writing. In case a complaint may be conveyed verbally to any member of the ICC, the member of the ICC to whom the complaint is made or any other member of the ICC shall render all reasonable assistance to the Aggrieved Person for making the complaint in writing.
Anonymous complaints cannot be accepted by ICC at any point in time.
Details to be mentioned in the complaint: The complaint must contain a description of the event (s) as well as the names and contact email/phone number of witnesses if any. Supporting documents, if available, such as letters, transcription of text messages etc. supporting the complaint of sexual harassment at workplace against the Respondent should accompany the complaint.
Form/Format of the complaint: The form in which the complaint is required to be made is attached as Annexure B to the Policy, and will be available with the ICC. However, any written complaint received in any form other than the form prescribed in Annexure B will be accepted provided the requisite details have been mentioned. The complaint can be submitted to the ICC electronically at icc@playo.co or may be physically submitted to any ICC member.
If a Complainant is unable to make their complaint in writing themselves: In the event that a Complainant is unable to lodge a complaint on account of any physical or mental incapacity or death or otherwise, his/her legal heir, co-worker or any person with knowledge of the incident may make a complaint to the ICC, but only with the written consent of the Complainant.
Processing a complaint
On receipt of a complaint, the ICC will acknowledge the receipt of the email by the Complainant within seven (7) working days. The further process of inquiry to be followed will be explained to the Complainant in their first meeting with the ICC.
Information about the Complainant’s identity: It is important for the Complainant to understand that even though the process is confidential, the Respondent will be informed of the Complainant and any witnesses and persons directly involved in the complaint process will also learn of the Complainant’s identity.
If the ICC determines that the complaint received is of sexual harassment at workplace and falls within the jurisdiction of the ICC, then it will proceed with the inquiry.
If the complaint does not fall within the definition of sexual harassment or within the ICC's jurisdiction, the complaint will be referred by the ICC to the relevant Human Resources Head for appropriate action under the relevant and applicable Company’s policy.
If the ICC decides to proceed with the inquiry, the ICC will send a copy of the written complaint to the respondent who is required to file its reply to the complaint with all supporting documents and list of witnesses (if any) within ten (10) working days of receiving the copy of the complaint.
Conciliation before inquiry
ICC may, before initiating an inquiry take steps to settle the matter between the Complainant and the Respondent through a process of conciliation. However, the ICC can only proceed with conciliation if the Complainant expressly requests for the same. No monetary settlement shall form the basis of the conciliation.
It is clarified that conciliation in itself does not necessarily mean acceptance of the offence having been committed by the Respondent, as mentioned in the complaint. It is a practical mechanism through which issues are resolved or misunderstandings are cleared.
If a settlement is arrived at, the ICC shall record the same, provide a copy to the Complainant and the Respondent and forward it to the Management of the Company for implementation. There shall be no further inquiry conducted by the ICC and the case shall stand closed. However, any criminal proceedings filed by the complainant under IPC or any other law for the for offences under the IPC or any other law in force will continue, independent of the settlement arrived through the ICC.
VIII. FORMAL INQUIRY TO BE CONDUCTED BY THE ICC
Important Guidelines with respect to inquiry conducted by ICC
Timeline: In case no conciliation is arrived at, ICC shall then initiate an inquiry and finish the inquiry process within ninety (90) days from the date of receipt of the complaint.
The internal timelines for the meetings with the Complainant, Respondent and witness will be decided by the ICC and communicated to the respective parties in the course of the inquiry.
The ICC shall follow principles of natural justice and fairness in all its proceedings and will maintain confidentiality of the identity of the Complainant, the Respondent and any witness involved with the inquiry.
The inquiry process provides for equal opportunity for both parties to be heard. The ICC will not prejudge the respondent’s guilt and will consider all evidence and witness(es) available to determine the outcome of the inquiry.
Production of evidence by Complainant and Respondent: Both parties have the right to produce oral or documentary evidence in their favor. Also, ICC has the right to call for and examine any other documents it deems fit for the purpose of the inquiry.
ICC’s right to call and examine witness: ICC has the right to call upon and examine the witnesses provided by the Complainant and the Respondent and any other person as they deem fit to the inquiry.
No legal practitioner can represent any party at any stage of the inquiry process.
Assistance to be taken by Complainant or Respondent: Both parties have an option of taking assistance of a co-worker or a family member for moral or emotional support during the inquiry. It is important to note that the individuals assisting and/or joining the ICC inquiry cannot act on behalf of the complaint or the respondent and shall only be present in meetings where their respective party (Complainant/Respondent) is present. The Complainant/Respondent shall intimate to the ICC the name and particulars of the person whom she/he desires to be present and ICC, in return, shall secure the confidentiality of all such members involved. These individuals are to adhere to the procedures as prescribed by the ICC and their presence may be denied by the ICC if any instance of violation of confidentiality is brought to the knowledge of ICC. The ICC has a right, with reasons to be recorded in writing, to decline the request of the Complainant/ Respondent to have such assistance.
Maintaining confidentiality:
The identity of the Complainant, Respondent, witnesses, statements and other evidence obtained in the course of inquiry process, recommendations of the ICC and action taken by the employer is considered as confidential, and not published or made known to public or media. Any person contravening the confidentiality clauses will be subject to disciplinary action as prescribed in the Act and internal policy of the Company.
All individuals who are part of the ICC inquiry will need to sign a confidentiality undertaking, the format of which will be decided upon by the ICC.
Strict consequences including but not limited to deduction or withholding of salary, permanent or temporary dismissal from the organization, and other disciplinary measures form part of the consequences in instances when an individual is found to have violated the confidentiality undertaking.
Refusal by any Employee of the Company to attend any hearing when summoned before the ICC or to provide any requested documents / information within his / her knowledge or possession shall constitute a misconduct as per this Policy and Company’s Code of Conduct and attract penalties/adverse action.
In case there is any need for travel for either the complainant or the respondent for the purpose of inquiry, the costs of travel and stay will be borne by the Company.
Important guidelines while conducting investigation
Quorum: In conducting the inquiry, it is mandatory for a minimum of 75% of the Members of the ICC, including the Presiding Officer to be present at each of the hearings.
Right to Cross examination: Both parties have the right to cross examine each other and the witness(es) provided by the other party. In situations when the woman Complainant does not wish to participate in a cross investigation in-person, cross examination can be conducted through a questionnaire which will be provided to the respondent via the ICC.
Interim Relief for the Complainant during the pendency of the inquiry
During the pendency of an inquiry, on a written request made by the woman Complainant, the ICC at their discretion, may recommend one or more of the following to the Management of the Company:
Transfer the Complainant or the Respondent to any other location or office of the Company;
Grant leave to the Complainant for a period upto three (3) months;
Restrain the Respondent from reporting on the work performance of the Complainant or writing his/her confidential report and assign the same to another officer
It is important to note that the leave granted to the Complainant shall be in addition to the leave she is otherwise entitled to.
On receiving a recommendation from the ICC, the Management of the Company shall implement the recommendations and send a report of such implementation to the ICC.
Termination of proceedings/ex parte decision
As per the Act, the ICC shall have the right to terminate the inquiry proceedings or to give an ex parte decision on the complaint, if the Complainant or Respondent fails to present herself or himself without sufficient cause for (3) three consecutive hearings convened by the Presiding Officer, after giving a fifteen days’ notice to the party concerned.
Record keeping
Every detail of the incidents, complaints, investigation, hearings, evidences, conclusions, agreements and closures will be documented and recorded in soft copy form by the ICC. These records will be maintained by the ICC in a safe and secure manner, and shall be shared with both the complainant and the respondent, as and when needed.
IX. FINAL INQUIRY REPORT BY ICC AND ITS IMPLEMENTATION
Final Inquiry Report
While preparing the inquiry report, ICC, among others, considers the following points:
Whether the language used (written or spoken), visual material or physical behaviour was of sexual or derogatory nature;
Whether the allegations or events follow logically and reasonably from the evidence;
Credibility of the evidence provided by the Complainant, Respondent and their witnesses; and/or
Other similar facts, evidence, for e.g. if there have been any previous accounts of harassment pertaining to the respondent
Actions to be taken after drafting the Inquiry Report
On the completion of the inquiry, the ICC shall provide a report of its findings to the Management of the Company within a period of 10 days from the date of completion of the inquiry.
A copy of the report should be given to the Complainant & Respondent.
When the Complainant’s allegations are not proved
Where the ICC concludes that the allegation against the Respondent has not been proved, it shall recommend to the Management of the Company that no action is required to be taken in this matter.
Further, upon sharing of the final report, the ICC will ensure that both parties understand that the matter has been fully investigated and concluded to the best of the efforts of the ICC and in alignment with the law, and this Policy.
When the Complainant’s allegations are proved
If the ICC arrives at the conclusion that the allegation against the Respondent has been proved, it shall recommend in writing to the Management of the Company to take action against the Respondent, which may include one or more among the following:
a written apology from the Respondent;
a letter of warning may be placed in the personal file of the Respondent;
reprimand or censure;
immediate transfer or suspension without pay;
withholding of pay rise or increment(s);
undergoing a counselling session;
carrying out community service; and/or
termination from service.
Recommendation by ICC for payment of compensation
The ICC may also recommend payment of compensation to the Complainant by the Respondent. For the purpose of determining the sum to be paid, the ICC shall take into account:
The mental trauma, pain, suffering and emotional distress caused to the Complainant
The loss in the career opportunity (caused to the Complainant) due to the incident(s) of sexual harassment;
Medical expenses incurred by the Complainant for physical treatment or counseling; and/or
Feasibility of such payment being made in lump sum or in installments.
ICC may also recommend the manner of collection of the compensation in its inquiry report as per the provisions of the POSH Act:
If the Respondent is still employed with the Company: to deduct the decided amount from the salary;
If the Respondent is no longer employed by the Company, to have the former pay the amount to the Complainant
If the Respondent fails to pay as per point 2, then the ICC can ask the District Officer (appointed under the Act) of the district of appropriate jurisdiction / where offices of the Company are located, to recover the sum as an arrears of land revenue.
The inquiry report of the ICC shall be treated as the final report and the recommendations of the ICC shall be implemented by the Company. The Company is provided sixty (60) daysto implement the recommendations of the ICC.
X. FALSE OR MALICIOUS COMPLAINTS
Where the ICC concludes that the allegation against the Respondent is malicious or the Complainant or any other person making the complaint has made the complaint knowing it to be false or the Complainant or any other person making the complaint has produced any forged or misleading document, it may recommend to the Management of the Company to take action against the person making the complaint.
While deciding malicious intent, the ICC shall note that the mere inability to substantiate a complaint need not mean malicious intent. Malicious intent must be clearly established through a separate inquiry that the ICC will conduct against the complainant.
The action recommended should be similar to the ones proposed for the Respondent in case of substantiated complaints.
In case a witness has given false evidence or produced any forged or misleading document during the inquiry, action may also be taken against the said witness in accordance with the applicable policy of the Company.
XI. APPEAL AGAINST THE INQUIRY CONDUCTED BY ICC
Any person aggrieved (Complainant or Respondent) by the recommendations related to the quantum or nature of penalties made by the ICC, or the non-implementation of such recommendations by the Managing Director, may file an appeal to the Appellate Authority in accordance with the Act and Rules within three (3) months from the date of the final inquiry report. (Such appellate authority is the respective Central Government Industrial Tribunal-cum-Labour Court appointed in various States).
XII. NON RETALIATION
This Policy seeks to encourage all Employees to express freely, responsibly, and in an orderly way opinions and feelings about any problem or complaint of sexual harassment. Retaliation against persons who report or provide information about sexual harassment or behavior that might constitute sexual harassment is also strictly prohibited. Any act of retaliation, including internal interference, coercion, and restraint by an Employee, violates this Policy and will result in appropriate disciplinary actions as per applicable policy of the Company.
It is important for all Employees to be aware that:
Retaliation will be treated as a misconduct under applicable policy of the Company.
Retaliation against those reporting sexual harassment will not be ignored under this Policy.
Retaliation would include any hurtful employment action against an individual/s.
Suspected or actual cases of retaliation must be reported to the ICC in writing.
Dissatisfaction with the response to a complaint of retaliation should be reported to the CEO directly.
XIII. Amendments & Updates
The policy will be reviewed from time to time and revised to keep it up to date with changes in state acts and employment policies. Company may make any alteration or amendment or rescind any of the clauses of this Policy as and when it finds it necessary to do so as long as it complies with the Act. Any such alterations or amendment or rescinding will be formally communicated to all the employees.
XIV. Exceptions
There are no exceptions to this policy.