POSH (Prevention of Sexual Harassment) POLICY

PALMARY PROJECTS & SERVICES PVT LTD

1. Introduction

The purpose of this policy is to prevent sexual harassment against women in the workplace and also to protect them. This policy is in accordance with the provisions of act. The Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressed) Act, 2013.Every Company aims to provide a safe working environment for all people.
This policy is applicable to all the members of the company including employer and those who are employed on regular, temporary, on a daily wage basis, etc.

The policy also extends to those who are not employees of the Palmary Project and Services Private Limited such as customers, clients, visitors, interns, contract workers, suppliers, etc. This policy is restricted to the business locations of the company and any external location visited by the employees during the course of employment. All the employees should have the personal responsibility to ensure that their behavior is not in contravention with the policy.

Any behavior which may be physical, psychological, graphical, emotional, verbal, written, electronic, gestures which are offending, etc. is defined as inappropriate by the policy. Any act of the person either intentional or not, should not offend the dignity of the other person. If done so then serious disciplinary action is taken against the person who has performed such act.

2. Scope

This policy applies to all employees, including permanent, temporary, contract, and outsourced staff, as well as visitors, vendors, and clients who interact with Company personnel at any location associated with work. It is applicable to all work-related interactions, including those occurring during business trips, company-sponsored events, conferences, and online communications. The policy covers both physical office premises and virtual workspaces, ensuring a safe and harassment-free professional environment.

3. Definition of Sexual Harassment

Sexual harassment includes, but is not limited to:

Category	Examples
Physical Harassment	Unwelcome physical contact and advances, inappropriate touching, blocking movement, or any physical interference that is unwarranted and offensive.
Verbal Harassment	Sexually suggestive comments, offensive jokes, derogatory remarks about gender or sexuality, repeated and unwelcome romantic advances.
Visual Harassment	Showing pornography, displaying sexually explicit images, sending inappropriate messages, lewd gestures, or suggestive expressions.
Non-Verbal Harassment	Staring, suggestive body language, whistling, or any behavior that creates a hostile work environment.

4. Internal Complaints Committee (ICC)

The Company has constituted an Internal Complaints Committee (ICC) to address sexual harassment complaints. The ICC is responsible for ensuring a fair and unbiased inquiry process and taking appropriate action against offenders. The ICC consists of:

Designation	Role	Name	Contact
Presiding Officer	Senior female employee with relevant experience in gender sensitivity and workplace safety.	Mrs. Sushma Kumari	9868262397
Employee Representatives	Two or more members from different departments to ensure diverse representation.	Mrs. Rachna	8375827617
		Mr. Abhijeet Kr. Singh	9958044425
External Member	An NGO or legal expert with experience in handling sexual harassment cases to provide an objective perspective.	Mr. Rajesh Chhikara	9991418004

The ICC is mandated to function independently and fairly, ensuring that complaints are handled with strict confidentiality and professionalism.

5. Complaint Filing Process

• • Any aggrieved person may submit a written complaint to the ICC within three months of the incident.
• • Complaints may be submitted via email, in writing to the ICC’s designated address, or through an anonymous complaint mechanism where applicable.
• • The ICC may extend the filing period in exceptional cases where the complainant was unable to file due to compelling circumstances.
• • Employees are encouraged to report incidents immediately, ensuring timely intervention and action.

Complaint Handling Steps:

• 1. Incident Occurs
• 2. Complaint Submitted to ICC
• 3. ICC Acknowledges Complaint
• 4. Inquiry Initiated
• 5. Hearing of Both Parties
• 6. Investigation & Report Submission
• 7. Management Decision & Action Taken

6. Inquiry Process

• • The ICC will conduct a fair, unbiased, and confidential inquiry within 90 days of receiving the complaint.
• • Both parties will be given an opportunity to present their case, including witnesses and supporting evidence.
• • The ICC may seek external expertise in complex cases to ensure thorough and impartial handling.
• • A report will be submitted to the management with recommendations for corrective measures or disciplinary action.
• • The Company shall implement the ICC’s recommendations within 60 days to ensure compliance and maintain a safe work environment.

7. Disciplinary Action

Disciplinary actions for those found guilty of sexual harassment will be proportionate to the severity of the offense. These may include:

Severity	Action
Minor Violation	Verbal or written warning, mandatory counseling, sensitivity training.
Moderate Violation	Transfer to another department, deduction in benefits, probationary period with behavioral monitoring.
Severe Violation	Suspension, termination, legal action, reporting to law enforcement authorities if necessary.

The Company maintains a strict stance against false or malicious complaints. If a complaint is found to be false with intent to defame, the complainant may also be subjected to disciplinary action as per the Company’s policies.

8. Confidentiality

• • The identity of the complainant, respondent, and witnesses shall be kept strictly confidential.
• • Any breach of confidentiality by any party involved in the inquiry process will lead to disciplinary action.
• • The ICC will maintain all complaint records securely and will not disclose details unless required by law or authorized personnel.
• • Employees are encouraged to report concerns without fear of retaliation, as the Company ensures protection against victimization of complainants and witnesses.

9. Awareness & Training

To ensure effective implementation of this policy, the Company will conduct periodic training and awareness programs:

Training Program	Frequency
Employee Awareness Session	Annually, with refresher sessions as needed.
ICC Training	Every six months to keep the committee updated on best practices and legal guidelines.
POSH Policy Refresh	Conducted as needed, especially after policy updates or legal amendments.

All employees are required to participate in these training programs to understand their rights and responsibilities under this policy.

10. Conclusion

Palmary Projects & Services Private Limited maintains a zero-tolerance policy towards sexual harassment. Employees are encouraged to report incidents without fear of retaliation. The Company is committed to fostering a respectful, safe, and inclusive workplace culture where all individuals can work with dignity and security.

For any queries or complaints, please contact: [hr@palmaryservices.com]

This policy is effective from [01-01-2022] and is subject to periodic review to ensure compliance with evolving legal and organizational requirements.