Shubham Housing Development Finance Company Limited (henceforth referred to as the "Company") is committed to providing a safe environment conducive to the growth and development of its all employees. Given this commitment, the Company strives to provide equal opportunities at employment, devoid of gender-based discrimination, coercion, intimidation or exploitation. The Company is dedicated to ensure enactment, observance and adherence to guidelines and best practices that prevent and prosecute commission of acts of sexual harassment. Hence, this anti sexual Harassment policy is being implemented (Policy)
The Policy is applicable for all acts of sexual harassment alleged to have taken place by individuals within or outside the Company premises where the Company conducts its business.
Any act of violation of this policy, by employees or third party interacting with the Company, will lead to appropriate remedial measures under the circumstances, including mitigation against the potential for repetition and to discipline any of its employees who may have participated in such conduct, or may have failed to stop such conduct when having the authority to do so.
The objective of this policy is to provide the definition, framework and modus operandi for addressing all allegations of sexual harassment made by any women employee and enable the implementation of provisions of Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 as modified from time to time (“the Act”).
To all women employees on the rolls of the Company and outsourced personnel working in the Company premises.
Sexual harassment includes, but will not be confined to the following:
The Company shall be responsible, among others, for the following:
It will be the responsibility of the Human Resource function to get an understanding of the issues raised and counsel the Complainant as well as the accused and make them aware of all implications of filing/ not filing a complaint formally.
In a scenario, wherein the Company / Committee becomes aware of commission of an act(s) of sexual harassment, the Company shall have the right to initiate suo moto action, even in the absence of a formal complaint being submitted by aggrieved women employee.
The Committee has been set up by the Company, which will address all cases/complaints of alleged sexual harassment submitted by the aggrieved women employee(s) or initiate suo moto by the Company, to prevent a deal with sexual harassment within the outlined framework. Further, Company may set up further committees or sub-committees, as and when Company deems fit.
The Committee consists of the following:
The Committee will meet as and when required.
The quorum requirement for convening a Committee meeting is 3 members. It is mandatory that atleast half of the members of the Committee are women and the Committee is led by a women member. Tenure of members and chairperson of Committee shall not exceed 3 years.
A person shall be disqualified for being appointed, elected nominated, designated for continuing, as a member of the Committee, if:-
It is the obligation of the Committee that all complaints of sexual harassment are treated and processed with utmost confidentiality, in alignment with the process outlined for required investigation and implementing corrective actions.
Any aggrieved women employee will have a right to lodge a complaint concerning sexual harassment against an employee or a third party interacting with the Company (henceforth referred to as "Complaint") with the Committee either in person or through an email to “email@example.com”, within a period of 3 months from the date of incident and in case of a series of incidents, within a period of 3 months from the date of last incident, in the manner as outlined below:
Provided that Anti-sexual harassment committee may, for the reasons to be recorded in writing, extend the time limit, not exceeding three months, if it is satisfied that the circumstances were such which prevented the woman from filing a complaint within the said period.
During the first meeting of the Committee, the Complainant shall be heard and the Committee shall decide whether the Complaint requires to be proceeded with. The Complaint will be dropped only if the Complainant will not able to substantiate an offence of sexual harassment.
In case the Committee decides to proceed with the Complaint, the Complainant’s concerns with respect to the issue shall be taken into account and if the Complainant so wishes, the Accused (henceforth referred to as "Accused") will be called to a meeting of the Committee, be heard and if necessary, warned about his / her behaviour and the matter concluded with a recording to that effect made by the Committee. However, if the Complainant wishes to proceed with the Complaint beyond a mere warning to the Accused, the same will be proceeded with in the manner prescribed in this policy under the ‘proceedings’ section.
The following is the redressal process, which will be adopted by the Committee to address any complaints lodged by an aggrieved women employee:
The Management will consider the recommendations and findings of the Committee and will be required to arrive at a decision with respect to the proposed corrective action against the accused with sixty (60) days of the submission of the report by the Committee.
The Management has the right to issue such order and / or directions as it deems fit. The Management shall also endorse a copy of its order to the Complainant, Accused and to the Committee.
The Management can impose the following penalties, which are indicative and not exhaustive on an employee who is found guilty of sexual harassment. These can be further classified as minor and major penalties, as follows:
Further, the employee may also be required to give a written apology to the complainant and upon his/her failure to do so, the penalty can be enhanced.
In case the act under sexual harassment amounts to a specific offence under the Indian Penal Code, 1860 or under any other applicable law, the Management shall initiate appropriate action, in accordance with law, by making a complaint with the appropriate authority.
The following will be obligations of the Company, during the processing / investigation of the Complaint:
Post conclusion of the investigations of the Complaint, the Company will observe the following:
The Committee reserves the right to modify and/ or review the provisions of this Policy, so as to comply with applicable legal requirements, internal policies, or with a view to align / alter the provisions of the policy to the extent deemed necessary by Committee from time to time.
There are no exceptions to this policy.
All queries and clarifications on the policy and procedures may be referred to the Human Resources Team of the Company