Policy Version – 2

Date of Issue – 21st January 2019

Document Reference No – HR/2019/02

POLICY ON PREVENTION OF SEXUAL HARASSMENT AT WORKPLACE

1. INTRODUCTION
The Government of India has made effective on April 22, 2013 a law called ‘The Sexual Harassment of
Women at Workplace (Prevention, Prohibition and Redressal) Act 2013’ on prevention of sexual
harassment against female employees at the workplace. The purpose of the act is to provide protection
against sexual harassment of women at workplace and for the prevention and redressal of complaints of
sexual harassment and for matters connected therewith or incidental thereto.

In accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and
Redressal) Act, 2013, the Company has framed and adopted a policy for Prevention of Sexual
Harassment at Workplace. This will be effective from 1st April, 2017.

The objective of the policy is to provide its women employees, a workplace, free from harassment/
discrimination and that every employee is treated with dignity and respect.


2. OBJECTIVE
To fulfill the directive of the Supreme Court of India enjoining all employers to develop and implement a
policy against sexual harassment of women at the work place or in the course of official duties. The policy
will remain applicable wherever employees have occasion to interact with each other including for
example, in vehicles, third party premises, off site meetings and public venues.

2.1 The Company is committed to provide a work environment that ensures every woman employee
is treated with dignity and respect and afforded equitable treatment.
2.2 The Company is also committed to promote a work environment that is conducive to the
professional growth of its women employees and encourages equality of opportunity.
2.3 The Company will not tolerate any form of sexual harassment and is committed to take all
necessary steps to ensure that its women employees are not subjected to any form of
harassment.
2.4 To uphold Women’s’ Right to Protection against Sexual Harassment and the Right to Livelihood
and towards that end for the prevention and redressal of Sexual Harassment of Women.
2.5 To ensure implementation of the Policy in letter and spirit by taking all necessary and reasonable
steps including but not limited to constitution of appropriate Committees for purposes of gender
sensitization and to conduct enquires into complaints of sexual harassment.

3. SCOPE
This policy applies to all categories of employees of the Company, including permanent, temporaries,
trainees and employees on contract at its workplace. The Company will not tolerate sexual harassment, if
engaged in by clients or by suppliers or any other business associates.

IRADIUM AUTOMOBILES PRIVATE LIMITED

CIN: U50401PN2013PTC148765
Office 405, Mont Vert Apex, Opp. Orchid School, Balewadi Phata. Baner. Pune. Maharashtra. 411045
020-65202588 | www.spareshub.com | [email protected]







The workplace includes:
3.1 All offices or other premises where the Company’s business is conducted.
3.2 All company-related activities performed at any other site away from the Company’s premises.
3.3 Any social, business or other functions where the conduct or comments may have an adverse
impact on the workplace or workplace relations.

4. DEFINITION OF SEXUAL HARASSMENT
“Sexual Harassment” includes any one or more of the following unwelcome acts or behavior (whether
directly or by implication) namely:-

a. physical contact and advances; or
b. a demand or request for sexual favors; or
c. making sexually colored remarks; or
d. showing pornography; or
e. any other unwelcome physical, verbal or non-verbal conduct of sexual nature;

4.1 The following circumstances, among other circumstances, if occurs or is present in relation to or
connected with any act or behavior of sexual harassment, may amount to sexual harassment:
a. Implied or explicit promise of preferential treatment in her employment; or
b. Implied or explicit threat of detrimental treatment in her employment; or
c. Implied or explicit threat about her present or future employment status;
d. Interference with her work or creating an intimidating or hostile or offensive work environment
for her with a purpose of interfering with an individual’s work performance ; or
e. Humiliating treatment likely to affect her health or safety.

5. 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.

6. COMPLAINT MECHANISM
Whether or not such conduct constitutes an offence under law or a breach of the service rules, 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.

7. INTERNAL COMPLAINTS COMMITTEE
The Company has instituted an Internal Complaints Committee for redressal of sexual harassment
complaint (made by the victim) and for ensuring time bound treatment of such complaints.

IRADIUM AUTOMOBILES PRIVATE LIMITED

CIN: U50401PN2013PTC148765
Office 405, Mont Vert Apex, Opp. Orchid School, Balewadi Phata. Baner. Pune. Maharashtra. 411045
020-65202588 | www.spareshub.com | [email protected]







Initially, and till further notice, the Complaints Committee will comprise of the following four
members out of which at least two members will be of the same gender as that of the
complainant:

Sr. No Name Designation Mobile No. Email – ID
1. Dr. Archana Gupta Chairperson 9997641500 [email protected]
2. Mr. Tapas Gupta Member 9730192588 [email protected]
3. Ms. Neena Lijo John Member 8308550416 [email protected]
4. Advocate Kavita Shivarkar Member 9730348170 --

7.1 The Internal Complaints Committee is responsible for:
a. Investigating every formal written complaint of sexual harassment.
b. Taking appropriate remedial measures to respond to any substantiated allegations of sexual
harassment.
c. Discouraging and preventing employment-related sexual harassment.

8. PROCEDURES FOR RESOLUTION, SETTLEMENT OR PROSECUTION OF ACTS OF SEXUAL
HARASSMENT
The Company is committed to providing a supportive environment in which the concerns of sexual
harassment shall be resolved as follows:

8.1 Informal Resolution Options
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.
b. 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 undertake prompt investigation to resolve the matter.

8.2 Complaints:
a. Any employee with a harassment concern, who is not comfortable with the informal resolution
options or has exhausted such options, may make a formal complaint to the Chairperson of the
Internal Complaints Committee constituted by the Management.

b. The mechanism for registering complaints should be safe, accessible and sensitive. All complaints
must preferably be brought by the complainant in person. All precaution will be taken to protect
the privacy of the individuals involved. Any aggrieved employee who is of the view that she is
being sexually harassed directly or indirectly, may submit a complaint of the alleged incident to
any or all the members of the Committee in writing with her signature within six months from the
date of occurrence of incident. It is also encouraged that both parties maintain records of all

IRADIUM AUTOMOBILES PRIVATE LIMITED

CIN: U50401PN2013PTC148765
Office 405, Mont Vert Apex, Opp. Orchid School, Balewadi Phata. Baner. Pune. Maharashtra. 411045
020-65202588 | www.spareshub.com | [email protected]


incidents, (such as, physical copies of emails, details of dates, places, witnesses and their feelings
at the time of the alleged harassment. Photographs,video/audio recordings submitted should be
tamper proof. These are useful, should a formal process come up).
c. Provided however that where such complaint cannot be made in writing, the Chairperson or any
Member of the Internal Complaints Committee, as the case may be, shall render all reasonable
assistance to the individual concerned for reducing the complaint in writing.

A written complaint with the following details must be submitted:

a. State the name of the alleged offender including designation and contact numbers;
b. State the date(s) and location(s) of the alleged incident(s) of harassment;
c. A detailed description of the incident(s) in question as well as other relevant circumstances; The
written complaint/email must provide the details of the incident together with the name/s of, the
alleged harasser/s and the victim/s, as available.
d. Names of witnesses and physical and/or documentary proof if any that supports the allegation;
including other potential complainants, if any;
e. Shall be signed and dated; no anonymous complaints shall be accepted by the Committee.
f. Complaint should include the contact details of the complainant / victim such as name, address,
contact number, department etc.;

8.3 The Chairperson of the Complaints Committee will proceed to determine whether the allegations
(assuming them to be true only for the purpose of this determination) made in the complaint fall
under the purview of Sexual Harassment, preferably within 30 days from receipt of the complaint.
In the event, the allegation does not fall under the purview of Sexual Harassment or the allegation
does not constitute an offence of Sexual Harassment, the Presiding Officer will record this finding
with reasons and communicate the same to the complainant.
8.4 If the Presiding Officer of the Complaints Committee determines that the allegations constitute
an act of sexual harassment, he/ she will proceed to investigate the allegation with the assistance
of the Complaints Committee.
8.5 Where such conduct, on the part of the accused, amounts to a specific offence under the law, the
Company shall initiate appropriate action in accordance with law by making a complaint with the
appropriate authority.
8.6 The Complaints Committee shall conduct such investigations in a timely manner and shall submit
a written report containing the findings and recommendations to the Employer as soon as
practically possible and in any case, not later than 90 days from the date of receipt of the
complaint. The Employer will ensure corrective action on the recommendations of the Complaints
Committee and keep the complainant informed of the same.
8.7 In the event of any delay in submission of the report, the reasons for the same shall be recorded
in writing by the Committee. The report of the committee shall be treated as an Inquiry Report on
the basis of which a delinquent employee shall be awarded appropriate punishment by the
employer of the company. The employer will act on the report of the committee in accordance
with the company rules.

9. MANNER OF TAKING ACTION AGAINST THE RESPONDENT
Where the Complaints Committee arrives at the conclusion that the allegation against the respondent
has been proved, it shall recommend to the employer to take action which may include the following:

IRADIUM AUTOMOBILES PRIVATE LIMITED

CIN: U50401PN2013PTC148765
Office 405, Mont Vert Apex, Opp. Orchid School, Balewadi Phata. Baner. Pune. Maharashtra. 411045
020-65202588 | www.spareshub.com | [email protected]



a. Written apology;
b. Communication / letter of warning to be sent to the employee and a copy of which shall be placed
in the personal file of that employee by Human Resources Department.
c. Immediate transfer or any other appropriate disciplinary action.
d. Withholding of Promotion;
e. Withholding of pay rise or increments; or
f. Terminating the respondent from service; or
g. Undergoing a counseling session or carrying out community service.
h. Filing of a complaint before the relevant statutory / police authorities / court of law;

10. PUNISHMENT FOR FALSE OR MALICIOUS COMPLAINT AND FALSE EVIDENCE
Where the Internal Complaints Committee arrives at a conclusion that the allegation against the
respondent is malicious or the aggrieved woman or any other person making the complaint has made the
complaint knowing it to be false or the aggrieved woman or any other person making the complaint has
produced any forged or misleading document, it may recommend to the employer to take action in
accordance with the provisions of the service rules applicable to her.

11. CONFIDENTIALITY
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 any investigatory process to
the extent practicable and appropriate under the circumstances.

12. 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.

13. 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 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.

14. MISCELLANEOUS:
1. Members of the ICC shall compulsorily undergo the training program formulated against sexual
harassment at workplace. The training program and workshops conducted shall include, but not
be limited to the following layout: i. Understanding the paradigms of the Act and scope of
definition of sexual harassment ii. Gender sensitization iii. Examples and case studies iv.
Procedural intricacies v. Orientation programs and seminars vi. Capacity building and skills
building. Such training program shall be conduct in the month of March, July and November every
year.

IRADIUM AUTOMOBILES PRIVATE LIMITED

CIN: U50401PN2013PTC148765
Office 405, Mont Vert Apex, Opp. Orchid School, Balewadi Phata. Baner. Pune. Maharashtra. 411045
020-65202588 | www.spareshub.com | [email protected]



2. The Internal Complaint Committee shall prepare an annual report and submit the same to the
district officer (a summary of which shall be submitted to the State Government) the following
details: i. Number of complaints of sexual harassment received during the year; ii. Number of
complaints disposed-off during the year; iii. Number of cases pending for more than 90 days; iv.
Number of workshops or awareness program against sexual harassment carried out; v. Nature of
action taken by the employer.


3. Awareness Initiatives-
• Mailer’s on the topic are regularly shared with employees.
• Use of Posters, Information booklets, etc. across the office and in common areas such as
lobbies, cafeteria.
• e-learning modules and e-books made available on the topic.
• An employee is expected to contact the HR or the Head of the Department, who will make
this information available.
• Employer shall also formulate and widely disseminate the internal policy; ii. Carry out
employee orientation and awareness programs at regular intervals iii. Declare names and
details of members of the ICC; iv. Use modules developed by the State Governments to
conduct workshops; v. Display at any place in the workplace, penal consequences of
sexual harassment.

15. CONCLUSION
In conclusion, the Company reiterates its commitment to providing its women employees, a
workplace free from harassment/ discrimination and where every employee is treated with dignity
and respect.


Employee Declaration



I ____________________________________, confirm that I have read the company policy on
Prevention of Sexual Harassment at Workplace and I would abide by it. Kindly take this on record.


Sign:

Name:

Designation:
Date:
Place:

IRADIUM AUTOMOBILES PRIVATE LIMITED

CIN: U50401PN2013PTC148765
Office 405, Mont Vert Apex, Opp. Orchid School, Balewadi Phata. Baner. Pune. Maharashtra. 411045
020-65202588 | www.spareshub.com | [email protected]