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Policy

Prevention of Sexual Harassment (POSH) Policy

Connect To India Private Limited is committed to a safe, respectful and equal workplace for everyone.

📅 Effective: 19 Aug 2021⚖️ As per POSH Act, 2013👥 Applies to all staff

Zero tolerance

We have a zero-tolerance policy for any act of sexual harassment, any suppression or distortion of facts or evidence, and any retaliation.

01Objective

Connect To India Private Limited has a zero-tolerance policy for any act of sexual harassment of any kind and any act of suppressing or distorting such facts or evidence, and retaliation. The company is committed to taking all necessary steps to ensure that its staff work in a safe and respectful environment that is conducive to their professional growth and promotes equality of opportunity.

02Scope & Applicability

This policy applies to all employees in the organisation, of any gender, including part-time employees, those on contract, and service providers deployed on the premises.

It covers acts that occur within the premises of the organisation or deemed premises within the organisation’s control.

This policy is owned by Connect To India Private Limited and can be reached at +91 98113 26655 and [email protected].

03Policy Statement

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, read along with its Rules of 2013 (the “Act”), states that no employee shall be subjected to sexual harassment at any workplace.

04Internal Complaints Committee

The Internal Complaints Committee (ICC) is constituted under the Act and is headed by a woman member of the organisation.

PoojaPresiding Officer
Director [email protected]+91 93157 76132
SandeepMember
Director [email protected]+91 97182 80692
Akhit KumarExternal Member
Labour Law Consultant [email protected]+91 97114 98168

05How to File a Complaint

Any aggrieved employee, or another person on their behalf as provided under the Act, can:

Step 1File a complaintWith the ICC within three months of the incident – by email to [email protected], in writing or verbally.
Step 2Conciliation (optional)Request settlement through conciliation before the ICC starts an inquiry.
Step 3InquiryThe ICC gives both sides a fair opportunity to present their case.
Step 4AppealAnyone aggrieved by the ICC report may appeal to the court within 90 days, as per the Act.

06ICC Duties & Inquiry

Responsibilities of the ICC

  • Investigate every formal written complaint of sexual harassment.
  • Give the aggrieved employee and the respondent a reasonable opportunity to present and defend their case.
  • Take appropriate remedial measures for any substantiated allegation.
  • Complete the inquiry within ninety days of accepting the complaint.

The inquiry process

The ICC examines every complaint as per the guidelines under the Act and ensures that a fair and just investigation takes place.

07Action the ICC Can Take

If it considers it appropriate, the ICC may recommend actions such as (not limited to):

Written apology
Warning, reprimand or censure
Termination from service
Compensation deducted from salary or wages
Withholding of promotion, pay rise or increments
Counselling or community service
Appropriate statutory or legal action

08False Complaints

Where the ICC concludes that a complaint was made with malicious intent, it shall take strict disciplinary action against the complainant, similar to the action for an act of sexual harassment. The ICC shall also take strict action against any witness who gives false evidence or produces forged or misleading documents.

09Definitions

Sexual harassment

Any unwelcome, sexually determined act or behaviour (directly or by implication), such as:

  • physical contact and advances
  • a demand or request for sexual favours
  • sexually coloured remarks
  • showing pornography
  • any other unwelcome physical, verbal or non-verbal conduct of a sexual nature

It also includes related circumstances such as promises of preferential treatment, threats of detrimental treatment or about employment status, interfering with work or creating a hostile environment, and humiliating treatment likely to affect health or safety.

Workplace

Any Connect To India office or premises, or any place visited by an employee during the course of employment, including transport provided by the company, and meetings, conferences, seminars, training sessions and workshops organised by or through the company.

Employee

A person employed at a workplace for any work on a regular, temporary, ad hoc or daily-wage basis, directly or through an agent or contractor, paid or voluntary – including co-workers, contract workers, probationers, trainees and apprentices.

10References

Connect To India Private Limited has the maximum discretion permitted by law to interpret, administer, change, modify or delete this policy at any time, with or without notice. This policy does not form part of any employee’s contract of employment unless explicitly stated in that contract, and is not intended to restrict communications or actions protected or required by law.

11Exceptions

Any deviation from this policy must be approved by HR. Any change to the policy must be approved by Legal and Compliance.

12Confidentiality

Anyone (including witnesses) who knows about an incident or the contents of a complaint must keep it strictly confidential. No such information may be published or shared in any way, including on the company intranet, internal messaging, email or social media. The company will take strict disciplinary action, including penalties under the Act, against anyone who breaches this duty of confidentiality.

No part of this document may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying or recording, for any purpose without the express written permission of the MD of Connect To India Private Limited.

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