POSH Policy

1. Purpose

The purpose of this POSH Policy is to establish guidelines to prevent, address, and redress complaints of sexual harassment in the HMM workplace, in compliance with applicable laws. This policy aims to create a safe, respectful, and inclusive work environment for all employees.

2. Scope

This policy applies to all employees, contractors, consultants, trainees, interns, and any other individuals engaged with the organization, whether at the workplace or at any work-related events, including off-site locations, and online interactions.

3. Definition of Sexual Harassment

Sexual harassment includes any unwelcome behaviour of a sexual nature, whether verbal, non-verbal, visual, or physical. Examples include, but are not limited to:

• Verbal: Unwelcome comments about a person’s appearance, lewd jokes, sexually explicit language, or repeated requests for dates.
• Non-Verbal: Gestures, displaying sexually explicit material, or suggestive looks.
• Physical: Unwelcome touching, patting, pinching, or any form of physical assault.
• Online: Sending sexually explicit emails, messages, or any unwelcome digital communication.

4. Prohibited Conduct

• Engaging in any form of sexual harassment as defined above.
• Retaliation against anyone who reports an incident of sexual harassment or participates in an investigation.
• False accusations of sexual harassment made with malicious intent.

5. Reporting Mechanism

• Complaint Process: Employees are encouraged to report incidents of sexual harassment as soon as possible. Complaints can be made verbally or in writing to the Internal Complaints Committee (ICC) or Mr. SK Arya DGM - HR personnel.
• Confidentiality: The organization will maintain the confidentiality of all complaints, investigations, and actions taken, to the extent possible, consistent with the need to conduct an adequate investigation.

6. Internal Complaints Committee (ICC)

• The organization shall constitute an ICC to address complaints of sexual harassment.
• The ICC will include a presiding officer Mrs. Rajani Madam at least two members from among employees committed to the cause of women or who have experience in social work or have legal knowledge, and one external member from an NGO or other body familiar with sexual harassment issues.
• The ICC will conduct a thorough and unbiased investigation of all complaints and recommend appropriate action based on the findings.

7. Investigation and Resolution Process

• Upon receipt of a complaint, the ICC will conduct a prompt, thorough, and fair investigation.
• Both the complainant and the respondent will have the opportunity to present their cases and provide evidence.
• Based on the investigation, the ICC will provide a report with its findings and recommendations to the employer.
• If sexual harassment is confirmed, the organization will take appropriate disciplinary action, which may include warnings, suspension, termination, or other legal remedies.

8. Consequences of Violation

Any HMM employee found to have violated this POSH Policy will be subject to disciplinary action, up to and including termination of employment, as well as possible legal consequences.

9. Training and Awareness

The organization will provide regular training sessions and awareness programs on sexual harassment and this POSH Policy for all HMM employees to ensure understanding and compliance.

10. Policy Review

This POSH Policy will be reviewed regularly to ensure it is up-to-date with applicable laws and effectively promotes a harassment-free workplace.

11. Acknowledgment

All HMM employees, contractors, and other individuals engaged with the organization are required to acknowledge that they have read, understood, and agreed to abide by this POSH Policy.