POLICY ON PREVENTION OF SEXUAL HARASSMENT AT WORKPLACE
Kashyap Tele-Medicines Limited (henceforth referred as “KTML” or “Company”) is committed to creating and maintaining a secure work environment where it’s Employees, Agents, Vendors and Partners can work and pursue business together in an atmosphere free of harassment, exploitation and intimidation caused by acts of Sexual Harassment within but not limited to the office premises and other locations directly related to the Company’s business.
The objective of this policy is to educate the employees about what conduct constitutes sexual harassment, the ways and means KTML adopt to prevent the occurrence of any such events and to provide protection against sexual harassment of women at workplace and redressal of complaints of sexual harassment and for matters connected therewith.
The Company is also committed to promoting a work environment that is conducive to the professional growth of its employees and encourages equal opportunities for all employees.
This policy applies to all categories of employees of the Company, including permanent management and workmen, temporaries, trainees and employees at their workplace or at client sites. The Company will not tolerate sexual harassment, if engaged in by clients or by suppliers or any other business associates.
The definitions given in The Sexual Harassment of Women at workplace (Prevention, Prohibition and Redressal) Act, 2013 will be applicable to the Company.
RESPONSIBILITIES REGARDING SEXUAL HARASSMENT
All employees of the Company have a personal responsibility to ensure that their behavior is not contrary to this policy. All employees are encouraged to reinforce the maintenance of a work environment free from sexual harassment.
INTERNAL COMPLAINTS COMMITTEE
A Committee has been constituted by the Management to consider and redress complaints of Sexual Harassment. The Chairman and Members of the Committee are as follows:
Dhruvil Shah (Presiding Officer)
A quorum of 2 members is required to be present for the proceedings to take place. The quorum shall include the any two members of the committee.
Any employee who feels he/she is being sexually harassed directly or indirectly may submit a complaint of the alleged incident to any member of the Committee, in writing with his/her signature, within 10 days of occurrence of incident.
The Committee will maintain a register to endorse the complaint received by it and keep the contents confidential if it is so desired, except to use the same for discreet investigation.
The Committee will hold a meeting with the Complainant normally within five days of the receipt of the complaint, but, in any case, no later than a week.
At the first meeting, the Committee members shall hear the Complainant and record her/his allegations. The Complainant can also submit any corroborative material with documentary proof, oral or written, etc., to substantiate her/his complaint. If the Complainant does not wish to depose personally due to embarrassment of narration of the event, a lady officer for lady employees involved and a male officer for male employees involved shall meet the complainant and record the statement.
Thereafter, the person against whom a complaint is made may be called for a deposition before the Committee and an opportunity will be given to him / her to give an explanation, whereafter, where warranted, a formal Enquiry shall be conducted.
In the event the complaint does not fall under the purview of Sexual Harassment or the complaint does not mean an offence of Sexual Harassment, the same would be dropped after recording the reasons thereof.
In case the complaint is found to be false or frivolous, the Complainant shall, if deemed fit, be liable for appropriate disciplinary action by the Management.
The Committee shall expeditiously proceed with the Enquiry and communicate the same to the Complainant and person against whom complaint is made.
The Committee shall prepare and hand over the Statement of Allegation to the person against whom complaint is made and give him / her an opportunity to submit a written Explanation, if he / she so desires, within 5 days of receipt of the same.
The Complainant shall be provided with a copy of the written explanation submitted by the person against whom complaint is made.
If the Complainant or the person against whom a complaint is made desires any witness/es to be called, they shall communicate in writing to the Committee the names of witness/es whom they propose to call.
If the Complainant desires to tender any documents or any other material by way of evidence before the Committee, she / he shall supply originals of such documents /material. Similarly, if the person against whom a complaint is made desires to tender any documents or material in evidence before the Committee he / she shall supply the originals.
The Committee shall call all the witnesses mentioned by both the parties to the enquiry.
The Committee shall provide every reasonable opportunity to the Complainant and to the person against whom a complaint is made, for putting forward and defending their respective case.
The Committee shall complete the Enquiry within a reasonable period, preferably within one month and communicate its findings and its recommendations for action to the Head-HR. The report of the Committee shall be treated as an enquiry report on the basis of which an employee can be awarded appropriate punishment straightaway by the management.
The Head-HR will facilitate appropriate action, keeping in view, the recommendation of the Committee.
OTHER POINTS TO BE CONSIDERED
The Committee may recommend to the Head-HR action which may include transfer or any other appropriate disciplinary actions, including termination from service.
The management shall provide all necessary assistance for the purpose of ensuring full, effective and speedy implementation of this policy.
Where sexual harassment occurs as a result of an act of omission or commission by any third party or outsider, KTML shall take all steps necessary and reasonable to assist the affected person in terms of support and preventive action.
The Committee shall analyse and put up a report on all complaints of this nature at the end of the year for submission to the CEO and the Board of Directors of the Company.
In case the Committee finds the degree of offence to be coverable under the Indian Penal Code, then this fact shall be mentioned in its report and appropriate action may be initiated by the Management for making a Police Complaint.
The Company understands that it is difficult for the victim to come forward with a complaint of sexual harassment and recognizes the victim’s interest in keeping the matter confidential.
To protect the interests of the victim, the accused person and others who may report incidents of sexual harassment, confidentiality will be maintained throughout the investigatory process to the extent practicable and appropriate under the circumstances.
ACCESS TO REPORTS AND DOCUMENTS:
All records of complaints, including contents of meetings, results of investigations and other relevant material will be kept confidential by the Company except where disclosure is required under disciplinary or other remedial processes.
PROTECTION TO COMPLAINANT / VICTIM:
The Company is committed to ensuring that no employee who brings forward a harassment concern is subject to any form of reprisal. Any reprisal will be subject to disciplinary action.
The Company will ensure that the victim or witnesses are not victimized or discriminated against while dealing with complaints of sexual harassment.
However, anyone who abuses the procedure (for example, by maliciously putting an allegation knowing it to be untrue) will be subject to disciplinary action.
In conclusion, the Company reiterates its commitment to providing its employees, a workplace free from harassment/ discrimination and where every employee is treated with dignity and respect.