POSH Policy

(Prevention of Sexual Harassment)

HappyLocate Relocation Services Pvt. Ltd.

As per the Sexual Harassment of Woman at Workplace

(Prevention, Prohibition and Redressal) Act, 2013
Dated: 29th November 2020

Document Approval

S. No. Document Approver Approver Designation Approver E-mail ID

1 Ajay Tiwari Director & CEO Ajay.tiwari@happylocate.com
2

Document Change History

Version Nature of Change Month and Year

1 First Release December 2020
The Sexual Harassment of Woman at Workplace
(Prevention, Prohibition and Redressal) Policy

Objective

We as a Company have always encouraged responsible and dignified conduct and behaviour, on the
part of all our employees, at all levels. Providing a safe and congenial work environment for women
employees is an integral part of a Company’s employment policy.

Sexual harassment of women at the workplace infringes fundamental right, to work in a safe and
healthy environment. Sexual harassment at the work place or other than work place if involving
employees is a grave offence and is, therefore, punishable.

We have zero-tolerance for sexual harassment. We value each and every employee working with us
and wish to protect their dignity and self-respect. In doing so, we are determined to promote a
working environment in which persons of both genders complement each other as equals in an
environment that encourages maximum productivity and to keep the personal dignity.

We at HappyLocate are committed towards giving every employee a just and fair hearing on issues
encountered by them at the workplace with special attention to sexual harassment. HappyLocate
will take very serious disciplinary action against any victimization of the employee who is
complaining or the alleged harasser that may result from a complaint.

The Company has accordingly framed “The Sexual Harassment of Women at the Workplace
(Preventions, Prohibition and Redressal) Guidelines” at establishments of HappyLocate; these
guidelines are available with the undersigned. Should any woman employee have a grievance of this
nature, she may approach the undersigned for details.

(Ajay Tiwari)
Director

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 The Sexual Harassment of Woman at Workplace
(Prevention, Prohibition and Redressal) Policy

GUIDELINES FOR PREVENTION OF SEXUAL HARASSMENT OF WOMEN AT THE WORKPLACE

1. Definitions and coverage
1.1 Sexual Harassment of women at workplace (Prevention, Prohibition and Redressal) Act, 2013
(“the Act”), has been enacted by the Parliament under which procedure of the redressal of
Sexual Harassment has been stipulated.
1.2 Based on the Act, HappyLocate Relocation Services Pvt. Ltd. (“the Company”) has framed ‘The
Sexual Harassment of Women at Workplace (Preventions, Prohibition and Redressal ) Guidelines
(hereinafter “the Guidelines”.) These guidelines extend to all Employees of the Company and
are deemed to be incorporated in the service conditions of all employees and are effective with
immediate effect.
1.3 “Employee” means a person employed at a workplace for any work on regular, temporary,
adhoc or daily wage basis, either directly or through an agent, including a contractor, whether
for remuneration or not, or working on a voluntary basis or otherwise, and includes a co-worker,
a contract worker, probationer, trainee, apprentice or called by any other such name.
1.4 For the purposes of these Guidelines, workplace shall mean and include all offices, premises,
project site, camp site, guest houses, temporary accommodations of the Company and/or
arranged by the Company and shall also include any place visited by the Employee arising out of
or during the course of employment including the transportation provided by the Company for
undertaking such journey.
1.5 These guidelines will also cover incidents of sexual harassment within the premises of the
company involving any non-employee and employee, where the aggrieved person is non-
employee and offender is an employee and, if the case is reported or comes to the notice of ICC,
the committee shall take cognizance of the same and initiate appropriate action.
1.6 Sexual harassment may include, but is not limited to, such unwelcomed sexually determined
behaviour (whether direct or by implication) as listed below:-
(a) Sexual advances, requests or demand for sexual favours, either explicitly or implicitly, in
return for employment, promotion, examination or evaluation of a person towards any
company activity;
(b) Sexual advances involving verbal, non-verbal, or physical conduct such as sexually
coloured remarks, jokes, letters, phone calls, e-mail, gestures, showing of pornography,
lurid stares, physical contact or molestation, stalking, sounds, display of pictures, signs,
verbal or non-verbal communication which offends the individual’s sensibilities and
affect her performance;
(c) Eve teasing, innuendos and taunts, physical confinement against one’s will and likely to
intrude upon one’s privacy;
(d) Act or conduct by a person in authority or otherwise which creates the environment at
workplace hostile or intimidating to a woman and causes mental stress and trauma for
her;

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 The Sexual Harassment of Woman at Workplace
(Prevention, Prohibition and Redressal) Policy

(e) Conduct of such an act at work place or outside in relation to an Employee of

HappyLocate or vice versa during the course of employment;
(f) Implied or explicit promise of preferential treatment in her employment;
(g) Implied or explicit threat of detrimental treatment in her employment;
(h) Implied or explicit threat about her present or future employment status;
(i) Interference with her work or creating an intimidating or offensive or hostile work
environment for her or humiliating treatment likely to affect her health or safety; and
(j) Any unwelcome gesture by an employee having sexual overtones.
1.7 Should any of these acts in any form be committed in circumstances where the victim feels
humiliated or threatened, such acts will be considered as “sexual harassment” of the female
employee. Likewise, when the female employee has reasonable grounds to believe that her
objections or refusal to consent to such actions would adversely affect her growth /
development prospects within the organisation or otherwise put her in a hostile office
atmosphere, such conduct will also be treated as one of “sexual harassment”.
1.8 The spirit in which the guidelines are framed ensures a safe and healthy environment for all and
it should be the endeavour of the aggrieved person to resolve the matter, with the support of
the Committee. A sense of restraint and responsibility on the part of all concerned is critical for
the effective functioning of these guidelines.

2. Prevention and Resolution of Sexual Harassment

2.1 HR Head will take appropriate steps to prevent sexual harassment in Corporate office as well as at
offices/sites, as follows: -
(a) Notify and circulate the Guidelines at work place, in appropriate way.
(b) Express commitment to eradicate and prevent sexual harassment and express
prohibition of sexual harassment.
(c) Display the Guidelines on the Company’s intranet.
(d) Appropriate work conditions has been provided in respect of work, leisure, health and
hygiene to further ensure that there is no hostile environment towards women at work
places and no woman employee has grounds to believe that she is disadvantaged in
connection with her employment.
(e) An appropriate complaint mechanism has been created at each office/site for redressal
of the complaint made by the victim. Such complaint mechanism, ensures time bound
treatment of complaints.
(f) Women employees working at the office/site are encouraged to write their complaints
to the Chairperson of the SHR Committee at Corporate Office or alternatively to any of
the Committee members also at Head Office.

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 The Sexual Harassment of Woman at Workplace
(Prevention, Prohibition and Redressal) Policy

(g) Anyone found guilty of harassment after investigation will be subjected to immediate
and appropriate disciplinary action at the recommendations of the SHR Committee.
(h) SHR Committee must submit an annual report to the Chairman, of the complaints, if
any, and the action taken.
(i) Awareness of the rights of female employees in this regard by prominently notifying the
guidelines in a suitable manner or by sending management representatives to seminars,
workshops organized by NGO or others.

3. Internal Complaints Committee (ICC)

3.1 A Committee (hereinafter referred to as “ICC”) shall be constituted by the Management to
consider and redress complaints of Sexual Harassment.
3.2 An ICC, as under, has been constituted to promptly look into the complaints: -

S. No. Name Department Role/Designation Contact details

8884333307/shweta.k@happylocate
(a) Shweta Kanashetti Corporate Sales Chairperson
.com
9739831248/misba.k@happylocate.
(b) Misba Khanum Pre Sales Team Member
com

8861378384/ajay.tiwari@happylocat
(c) Ajay Tiwari CEO Office Member
e.com
9686322004/sainadh.duvvuru@hap
(d) Sainadh Duvvuru Corporate Sales Member
pylocate.com
9819949180/swapnaraj.rege@gmail.
(e) Swapna Rege External Member External Member
com

4. Management of Complaint by ICC

4.1 The following are the guidelines: -
(a) There shall be quarterly meetings with female employees at the Head Office, with an e-
mail to all women employees at sites by the ICC to discuss the grievances or
inconveniences of the female employees at workplace. In case of an incident between
quarterly meetings, the ICC will meet at its earliest convenience, to resolve the issue.
(b) Minutes of the meetings will be recorded and discussed with the other members of the
Committee. The minutes of the meeting will be signed by the Chairperson of ICC.
(c) It is the responsibility of the ICC to investigate all incidents of sexual harassment and
recommend appropriate corrective or disciplinary action.

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 The Sexual Harassment of Woman at Workplace
(Prevention, Prohibition and Redressal) Policy

(d) Any woman employee who feels she is being sexually harassed directly or indirectly may
submit a complaint of the alleged incident to any member of the ICC in writing with her
signature within three months of occurrence of incident and in case of series of
incidents, within three months of the last incident.
(e) The complainant shall submit to the ICC of the complaint along with supporting
documents, if any, and the names and addresses of the witnesses either through email
or hard copy.
(f) On receipt of the complaint, the ICC shall send one of the copies received from the
aggrieved woman to the respondent within a period of 5 working days.
(g) The respondent shall file his reply to the complaint along with his list of documents and
names and addresses of witnesses, within a period not exceeding 5 working days from
the date of receipt of the documents.
(h) The ICC may, before initiating an investigation and at the request of the complainant,
take steps to settle the matter between her and the respondent through conciliation. A
copy of the settlement so arrived at shall be given to complainant and the respondent
and a report thereof shall be submitted to the management. In cases of settlement, no
further enquiry shall be done.
(i) If not settlement is possible, the person against whom complaint is made shall be called
for a deposition before the ICC and an opportunity will be given to him to give an
explanation, thereafter, an “Enquiry” shall be conducted and concluded.

5 Investigation Procedure
5.1 The following investigation process needs to be conducted: -
(a) The ICC shall immediately proceed with the Enquiry and communicate the same to the
Complainant and person against whom complaint is made.
(b) The ICC shall prepare and hand over the Statement of Allegation to the person against
whom complaint is made and give him an opportunity to submit a written explanation if
he so desires within 72 Hours of receipt of the same.
(c) The Complainant shall be provided with a copy of the written explanation submitted by
the person against whom complaint is made.
(d) If the Complainant or the person against whom complaint is made desires any
witness(es) to be called, they shall communicate in writing to the ICC the names of
witness(es) whom they propose to call.
(e) The ICC shall provide every reasonable opportunity to the Complainant and to the
person against whom complaint is made, for putting forward and defending their
respective case.

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 The Sexual Harassment of Woman at Workplace
(Prevention, Prohibition and Redressal) Policy

(f) The ICC shall complete the enquiry within reasonable period but not beyond 90 days
and communicate its findings and its recommendations for action to the management.
(g) Each allegation of sexual harassment will be investigated in a prompt, diligent and
thorough manner. The findings and conclusion will be reviewed with employees
involved in the alleged incident or conduct. If after the investigation, management finds
that an employee has violated the policy against sexual harassment, appropriate action
will be taken.
(h) Should the complainant so desire, the ICC would recommend to HR for prompt shifting
of the complainant to a different department/vertical during the pendency of
investigation or such further duration as may be appropriate.
(i) Should the ICC find that elements of criminality are also involved and complainant so
desire, it shall recommend that the Company or the Complainant files a complaint with
the police.

6 Confidentiality
6.1 Investigations will be conducted in a manner as to respect and protect the privacy of the parties
concerned to the extent possible.
7 False Accusations
7.1 False accusations of sexual harassment can have serious or devastating effect on innocent
person. While endeavouring to protect employees from sexual harassment, the company would
also ensure that its employees are not subjects to unwarranted, reckless or malicious complaints
of harassment.
Therefore, if after investigation or enquiry it becomes clear that the complainant had made a
false accusation maliciously or recklessly, the complainant would become liable for appropriate
disciplinary action, which may even include dismissal from services.

8 Sexual Harassment by a Third Party

8.1 When sexual harassment is through a third party or an outsider, the employer and person in
charge will take all steps necessary and reasonable to assist the affected person in terms of
support and prevention action.

9 Communication of the SHR Policy

9.1 The policy on sexual harassment will be communicated to all the employees. All the managers
and supervisors are responsible for knowledge and creating awareness about the policy.
10 Supports from NGO

10.1 “Name of NGO” being a recognized NGO, will assist as and when warranted, particularly during
complaint redressals.

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