Connection Zindagi Ka

POLYCAB INDIA LIMITED

POLICY ON PREVENTION OF SEXUAL HARASSMENT AT WORKPLACE
DOCUMENTATION CONTROL
Company: Polycab India Limited Adoption and Effective Date: 30th August 2018
Revision 1 : 23rd October 2019
Document Title: Policy on Revision 2 : 13th May 2021
Prevention of sexual harassment at
workplace

REVISION HISTORY
Revision Requester Description of Change
1 Secretarial The Policy is being amended to capture the reconstitution of the
Team Internal Complaints Committee in accordance with the
requirements of the Sexual Harassment of Women at Workplace
(Prevention, Prohibition and Redressal) Act, 2013.
DOCUMENT CHANGE APPROVAL

Initiate Change Obsolete

Objective : The policy is to set a guiding principle to provide every employee and associated
parties the right to work in an environment free from harassment, intimidation or offensive
behaviour and in which issues of harassment shall be resolved without fear of reprisal.

Approval
Name Designation Signature Date

All information herein is company proprietary and property of Polycab India. It shall not
be reproduced or copied unless as expressively permitted or directed by Polycab.
1. Background: Polycab India Limited (hereinafter referred to as the "Polycab") is
committed to provide equal opportunity and a harassment free workplace
notwithstanding race, caste, religion, colour, ancestry, marital status, gender, sexual
orientation, age, nationality, ethnic origin or disability, as the case may be. With a view
to create a safe and conducive work environment, this Policy has been framed, in line
with the provisions of the "Sexual Harassment of Women at Workplace (Prevention,
Prohibition and Redressal) Act, 2013" of India (hereinafter referred to as the "Act") and
existing rules framed thereunder namely the "Sexual Harassment of Women at
Workplace (Prevention, Prohibition and Redressal) Rules, 2013 (hereinafter referred to
as the "Rules").

2. Applicability: This Policy covers all employees of Polycab India Limited and is
applicable with immediate effect.

3. Scope:
a) This policy applies to all employees full-time, part-time, trainees and those on
contractual employment of the Company at their workplace.
b) The Policy also applies to the Employees of business associates ("associated
parties") who visit workplace for official duties.
c) The workplace includes
1. All offices or other premises where the Company's business is conducted.
2. All company-related activities performed at any other site away from the
Company's premises.

4. Objective: Provide every employee and associated parties the right to work in an
environment free from sexual harassment, intimidation or offensive behaviour and in
which issues of harassment shall be resolved without fear of reprisal.

5. Definitions:
a) "Respondent" means a person against whom complaint is made.
b) "Employee" means person employed on workplace for full-time, part-time,
including person employed as trainees and on contract basis.
c) "Internal Complaints Committee / Complaints Committee / Internal Committee":
An internal complaints committee constituted under Section 4 of the Sexual
Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act,
2013 "The Act"
d) "Presiding officer": means the Presiding Officer of Internal Complaints Committee
nominated under sub-section 2 of section 4 of the Act.
e) "Sexual harassment" would mean and include any of the following:
i. Unwelcome 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;
ii. Unwelcome 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 individuals sensibilities and affects her/his
performance;
iii. Eve teasing, and taunts, physical confinement against one's will and likely to
intrude upon one's privacy;
 iv. Act or conduct by a person in authority which creates the environment at
workplace hostile or intimidating to a person belonging to the other sex;
v. Conduct of such an act at workplace or outside in relation to an Employee at
Polycab, or vice versa during the course of employment;
vi. Any unwelcome gesture by an employee having sexual overtones;
vii. It is sexual harassment if a Superior requests sexual favours from a junior in
return for promotion or other benefits or threatens to sack for non
cooperation. It is also sexual harassment for a boss to make intrusive
inquiries into the private lives of employees, or persistently ask them out. It
is sexual harassment for a group of workers to joke and snigger amongst
themselves about sexual conduct in an attempt to humiliate or embarrass
another person.
f) “Management” means the Chairman & Managing Director or any other
person(s) authorised by him

6. Responsibility regarding sexual harassment:

All employees of the Company have a personal responsibility to ensure that their
behaviour is not contrary to this policy. All employees are encouraged to reinforce the
maintenance of a work environment free from sexual harassment.

7. Complaint Mechanism:
An appropriate complaint mechanism in the form of Internal Complaints Committee" has
been created in the Company for time-bound redressal of the complaint made by the
victim.

8. Constitution of Internal Complaints Committee:

A Committee shall be constituted by the Management called the Internal Complaints
Committee to consider and redress complaints of Harassment at every office/
administrative units/ workplace/ factory location of the Company.

The Presiding Officer and Members of the Committee are as follows:

Sr. Category Name of the designated member
No.
1 Presiding Officer Senior level woman employee of the Company
2 Member Minimum Two employee members preferably committed
to the cause of women or who have experience in social
work or have legal knowledge
3 Member from an Amongst Non-Government Organization or Association
NGO / Lawyer committed to the cause or a person familiar with the
(Member) / any issues relating to sexual harassment.
external body

The ICC shall be reconstituted by the Management from time to time in

compliance with the Act and the rules framed thereunder
 a) A quorum of three members is required to be present for the proceedings to take
place. The quorum should include the Presiding officer, at least two members, one of
whom shall be a lady.
b) The Presiding officer and every member of the committee shall hold office not
exceeding 3 years from the date of their nomination.
c) The member appointed from amongst non - governmental organization or
associations shall be paid such fees or allowances for holding the proceedings of the
internal committee as may be prescribed.
d) Where the presiding officer or any member of the Committee:
i. Contravenes the provisions of section 16 of the Act. (disclosure identity of
aggrieved women, respondent and witnesses); or
ii. Has been convicted of an offence or an enquiry into an offence under any law for
the time being in force is pending against him / her; or
iii. He / she has been found guilty in any disciplinary proceedings or a disciplinary
proceeding is pending against him / her; or
iv. Has so abused his/ her position as to render his/her continuance in office
prejudicial to the public interest.
Such presiding officer or member, as the case may be, shall be removed from the
Committee and the vacancy so created or any casual vacancy shall be filled by fresh
nomination in accordance with the provision of section 4 of the Act.

e) The Presiding Officer reserves the right to nominate more members of appropriate
seniority and rank in the committee to conduct such enquiries to ensure equal
representation of the gender as that of the complainant or for any other valid reason.

f) The internal committee shall in each calendar year prepare in such form and at such
times as may be prescribed an annual report and submit the same to the management
and District Officer.

g) The Complaints Committee is responsible for

i. Inquire into every formal written complaint of sexual harassment
ii. Make appropriate recommendations and remedial measures to respond to any
substantiated allegations of sexual harassment
iii. Discouraging and preventing employment-related sexual harassment

9. Complaint
a) When an incident of sexual harassment occurs, the victim of such conduct can
communicate their disapproval and objections immediately to the harasser and
request the harasser to behave decently.
If the harassment does not stop or if victim is not comfortable with addressing the
harasser directly, the victim can bring their concern to the attention of the Complaints
Committee for redressal of their grievances. The Complaints Committee will
thereafter provide advice or extend support as requested and will conduct inquiry to
resolve the matter.
b) Any employee who feels and is being sexually harassed, may submit a complaint of
the alleged incident, giving the details of such harassment to the any of the members
of the Committee in writing with his/her signature within 3 months from the date of
the incident and in case of a series of incidents, within a period of 3 months from the
date of the last incident.
c) Provided further that the Internal Committee or, as the case may be, the Local
Committee may, for the reasons to be recorded in writing, extend the time limit not
exceeding another three months, if it is satisfied that the circumstances were such
which prevented the woman from filing a complaint within the said period.

d) Where the aggrieved woman is unable to make complaint on account of her physical
or mental incapacity or death or otherwise, her legal heir or such other person as may
be prescribed may make a complaint under this section.

e) The Committee shall maintain a register to endorse the complaint received by it and
keep the contents confidential, except to use the same for discreet investigation.

f) The Committee will hold a meeting with the Complainant within five days of the
receipt of the complaint, but not later than a week in any case.

g) The Committee may before initiating an inquiry at the request of the complainant
takes steps to settle the matter between the complainant and the accused through
conciliation.

h) At the first meeting, the Committee members shall hear the Complainant and record
the her statement under oath. The Complainant can also submit any corroborative
material with a documentary proof, oral or written material, etc., to substantiate the
complaint. If the Complainant does not wish to depose personally due to
embarrassment of narration of event, a lady officer for lady employees involved and
a male officer for male employees, involved shall meet and record the statement.

The Committee shall forward a copy of the complaint to the respondent alongwith
supporting documents and name of the witnesses within 7 working days of receipt of
the same and the respondent needs to reply within 10 working days alongwith
supporting documents and name of witnesses. The Complainant shall be provided
with a copy of the reply submitted by the respondent.

i) Thereafter, the accused may be called for a deposition before the Committee and an
opportunity will be given to provide an explanation and any corroborative material
i.e. documentary proof, oral or written material, etc., to substantiate his contentions,
whereafter, an "Enquiry/' shall be conducted and concluded. Where both parties are
employees, the parties shall during the course of enquiry be given an opportunity to
be heard and a copy of the finding shall be made available to both the parties enabling
them to make representation against the findings before the Internal Complaints
Committee

j) 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.

k) In case the complaint is found to be false, the Complainant shall, if deemed fit, be
liable for appropriate disciplinary action by the Management.
 l) The Committee shall within 5 days proceed with the inquiry and communicate the
same to the Complainant and the accused.

m) The Committee shall prepare and hand over a Statement of Allegation to the accused
and give an opportunity to submit a written explanation if such person so desires
within 7 days of receipt of the same.

n) The Complainant shall be provided with a copy of the written explanation submitted
by the accused.

o) If the Complainant or the accused 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.

p) If the Complainant desires to tender any documents by way of evidence before the
Committee, she / he shall supply original copies of such documents. Similarly, if the
accused desires to tender any documents in evidence before the Committee he / she
shall supply original copies of such documents. Both shall affix his / her signature on
the respective documents to certify these to be original copies.

q) The Committee shall call upon all witnesses mentioned by both the parties.

r) The Committee shall provide every reasonable opportunity to the Complainant and
to the accused, for putting forward and defending their respective case.

s) The Committee shall complete the "Inquiry" within reasonable period but not beyond
three months and communicate its findings and its recommendations for action to the
Management. The report of the committee shall be treated as an inquiry report on the
basis of which an erring employee can be awarded appropriate action by way of
Warning (Verbal / Written) / Suspension / Termination. appropriate action.

t) The Management will direct in accordance with the recommendation proposed by

the Committee.

u) Corrective action may include any of the following:

i. Formal apology
ii. Counselling
iii. Written warning to the perpetrator and a copy of it maintained in the employee's
file.
iv. Change of work assignment / transfer for either the perpetrator or the victim.
v. Suspension or termination of services of the employee found guilty of sexual
harassment.

10. Duties of Management:

Management shall:
a) Provide a safe working environment at the workplace which shall include safety from
the person coming into contact at the workplace.
b) Display at any conspicuous place at the workplace, the penal consequences of sexual
harassment and regarding constitution of internal committee.
 c) Organize workshops and awareness programs at regular intervals for sensitizing the
employees with the provisions of the act and orientation programmes for the
members of the internal committee in the manner as may be prescribed.
d) provide necessary facilities to the Internal Committee for dealing with the complaint
and conducting inquiry.
e) assist in securing the attendance of the accused and witnesses before the Internal
committee.
f) make available such information to the Internal committee as it may require having
regard to the complaint made.
g) provide assistance to the woman employee if she so chooses to file a complaint in
relation to the offence under the Indian Penal Code or any other law for the time
being in force
h) cause or initiate action under the Indian Penal Code or any other law for the time
being in force, against the perpetrator or the if the aggrieved women employee so
desires where the perpetrator is not an employee in the workplace at which the
incidence of sexual harassment took place
i) treat sexual harassment as a misconduct under the service rules and initiate action for
such misconduct.
j) monitor the timely submission of reports.

11. Confidentiality:
The identity of the complainant, respondent, witnesses, statements and other
evidence obtained in the course of inquiry process, recommendations of the
committees, action taken by the employer is considered as confidential materials,
and not published or made known to public or media. 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 process.
Any person contravening the confidentiality clauses is subject to disciplinary action as
prescribed in the act.

12. Protection to Complainant/Victim:

The Company, while dealing with complaints of sexual harassment will not
victimize or discriminate against the complainant or witness who brings forward a
harassment concern. is subject to any form of reprisal and reprisal will be subject to
disciplinary action.

******************************************