POLICY FOR PREVENTION OF SEXUAL HARASSMENT (POSH)

1. PURPOSE:

To create and maintain safe work environment, free form sexual harassment & discrimination for all its employees. As per the guidelines of “The Sexual harassment of women at workplace (prevention, prohibition & redressal) Act, 2013,

2. SCOPE:

Bharat Group aims to adopt zero tolerance attitudes against any kind of Sexual Harassment or discrimination caused by any employee during their tenure in Bharat Group towards any other person being an employee of Bharat Group, Client, Vendor and Contractor in Company premises or elsewhere in India or abroad.

3. APPLICABLITY:

All employees of Bharat Group at all locations.

4. DEFINITION:

1. Employee of Bharat Group – Includes person carrying out any work on behalf of Bharat Group and may have been hired as Permanent, Temporary, Contracted or on Retainership Basis, part-time basis etc either directly or indirectly or through vendor organization.

2. Sexual Harassment – Harassment of a Female/Male employee consisting of any unwelcome sexually determined behavior, whether directly, indirectly, by any male/female in charge of the management or a male/female co-employee either individually or in association with other persons to exploit the sexuality of co-employee to harass him/her in manner which prevents or impairs his/her full utilization of full benefits, facilities or opportunities or any other behavior which is generally considered to be derogatory .

3. Aggrieved Women - In relation to workplace, a woman of any age whether employed or not, who alleges to have been subjected to any act of sexual harassment by the Respondent.

4. Respondent: Employees against whom the complaint has been filed.

5 POLICY GUIDELINES:

Sexual Harassment shall include but not limit to:-

• Physical Contact & Sexual advances
• Demand or request for sexual favors;
• Sexually- coloured remarks;
• Showing pornography;
• Any other unwelcome physical, verbal or non-verbal or written conduct of a sexual nature.

6. GRIEVANCE MECHANISM:

A complaint shall be submitted in writing to the Internal Committee mentioned herein within 1 month of occurrence of an act of Sexual Harassment.

7. INTERNAL COMMITTEE:

a. Each complaint of Sexual Harassment shall be dealt with utmost confidentiality and urgency by an Internal committee consisting of:

S.N.	Name of the Member	Designated As
1	BGeneral Manager - Regulatory Affairs	Chairperson
2	Company Secretary	Member
3	Commercial Executive	Member
4	Sr. Manager – Finance & Accounts	Member
5	Practicing Company Secretary - Outside Organization Member	Member

b. Within 3 working days, the Internal committee shall commence Official Internal Enquiry by:

• By informing the said complaint to the respondent.
• By instructing to stop the alleged act of Sexual Harassment immediately
• By informing not to reach out to the complainant directly or indirectly
• . BY asking an immediate explanation from him/her to the same

c. Within 5 working days from the receipt of original complaint, the designated person shall respond in writing to the complainant informing him/her about the initial steps taken by the Company in order to stop the alleged act(s)

d. Within 15 days from receipt of the original complaint, the Internal committee shall record and accordingly communicate in writing to the complainant and the Respondent, its prima facie findings, upon giving the concerned parties a fair and due opportunity to represent themselves and upon conducting fact finding, truth verification and counseling sessions with persons involved in alleged act(s).

e. A complaint will be closed no later than one month from receipt of original complaint by recording the decisions of the internal committee, accordingly informing to the complainant and the Respondent of the same.

f. Employees are duty bound to assist in investigative steps, employees’ wholehearted participation shall be mandatory in this regard. Whistleblowers shall be protected from exposure, retaliation or hostility.

g. Within 2 working days from receipt of prima facie findings or the charges, if the complainant or the Respondent is dissatisfied with the decision of internal committee, she or he may appeal specifying the reasons in writing to Managing Director. Within 5 working days from the receipt, the appeal shall be finally disposed of by written communication to the said party.

8. REDRESSAL:

1. An amicable resolution of the complaint is possible only with the written consent of the complainant.

2. Within 24 hours of closing the case file, the internal committee shall present the same to and inform its decision to the Managing Director.

3. In case of decision establishing the offence of Sexual Harassment of the complainant, within 3 working days, the internal committee shall recommend Disciplinary action against the offender considering the nature and extent of injury caused to the complainant, prior complaints or repetition of offence etc and the impact of the offence on the company profile as a whole.

4. The position of the offender and the criticality of the position occupied by the offender shall not be any hindrance to the disciplinary action taken against the offender.

5. The disciplinary action that shall be commensurate with the nature of the gravity of the offence, shall include but not limited to,

• Warning
• Written apology from offender
• Bond of good behavior
• Denial of employee benefits like increments/promotion/salary correction etc. - Cancellation of specific work Assignment
• Suspension
• Dismissal

Annual report summarizing complaints and Redressal of Sexual harassment shall be prepared by designated person. The said report as well as all documents regarding Sexual Harassment complaints shall be in the custody of designated person and will be termed as ‘Strictly Confidential’.

9 REVIEW:

This policy may be reviewed by the Board of Directors of the Company to ensure it meets the requirements of legislation & the needs of organization.