Prevention of Sexual Harassment (POSH) Policy

1. Objective

The objective of the Prevention of Sexual Harassment (POSH) Policy is to provide a safe and respectful working environment at Vertotech Aerospace Ltd. (hereinafter referred to as "the Company") where all employees are free from any form of sexual harassment. This policy aims to prevent, address, and resolve instances of sexual harassment in the workplace and ensure compliance with legal requirements under the Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act, 2013.

2. Scope and Applicability

This Policy applies to:

  • All employees of the Company, including permanent, temporary, and contractual staff.
  • All individuals associated with the Company, including visitors, clients, contractors, and suppliers.
  • The Policy covers all aspects of work-related interactions, including in the workplace, during work-related events, and while traveling for work.

3. Definition of Sexual Harassment

Sexual harassment includes any unwelcome act or behavior of a sexual nature that creates an intimidating, hostile, or offensive work environment. It includes but is not limited to:

  • Physical Contact: Unwelcome physical contact, touching, or advances.
  • Verbal Harassment: Unwelcome remarks, jokes, comments, or questions of a sexual nature.
  • Non-Verbal Harassment: Unwelcome gestures, displaying sexually explicit material, or making suggestive comments.
  • Quid Pro Quo Harassment: Imposing any condition or expectation for employment benefits in exchange for sexual favors.
  • Hostile Work Environment: Conduct that creates a work environment that is intimidating, hostile, or offensive due to its sexual nature.

4. Responsibilities

a) Management
  • Implementation: Ensure the effective implementation of this Policy.
  • Training: Provide training and awareness programs on sexual harassment prevention.
  • Support: Create a supportive environment for individuals who raise complaints and ensure confidentiality.
b) Employees
  • Respect: Treat all colleagues with respect and dignity.
  • Reporting: Report any incidents of sexual harassment to the Internal Complaints Committee (ICC) or the designated authority.
  • Cooperation: Cooperate with investigations and resolution processes.

5. Internal Complaints Committee (ICC)

Composition:

The ICC shall consist of a Presiding Officer (a senior woman employee), two or more members from the Company’s workforce, and at least one external member from an NGO or organization committed to women’s welfare.

Role and Responsibilities:
  • Receive Complaints: Receive and register complaints of sexual harassment.
  • Investigate: Conduct a fair and impartial investigation into the complaints.
  • Report: Prepare and submit an investigation report with recommendations to the management.
  • Confidentiality: Maintain confidentiality throughout the process.

6. Complaint Procedure

a) Filing a Complaint
  • Method: Complaints can be filed in writing or verbally to the ICC, through email, or through a complaint box if available.
  • Timeline: Complaints should be made as soon as possible, ideally within three months of the incident.
b) Investigation
  • Procedure: The ICC shall conduct an inquiry into the complaint, providing both the complainant and the accused an opportunity to present their cases.
  • Outcome: Based on the investigation, the ICC shall make recommendations for action, which may include disciplinary measures, counseling, or other remedies.

7. Disciplinary Action

Depending on the findings of the ICC, disciplinary action may be taken against the perpetrator. This can include:

  • Warning or Reprimand: Verbal or written warning.
  • Suspension: Temporary suspension from duties.
  • Termination: Termination of employment or contract.

8. Protection Against Retaliation

The Company prohibits retaliation against individuals who file a complaint or participate in an investigation. Retaliatory actions will be considered a violation of this Policy and will be subject to disciplinary action.

9. Training and Awareness

The Company shall conduct regular training and awareness programs on sexual harassment for all employees, including new hires, to ensure understanding and compliance with this Policy.

10. Review and Amendments

The Policy shall be reviewed periodically to ensure its effectiveness and relevance. Any amendments or updates to the Policy shall be approved by the Board of Directors and communicated to all employees.

11. Disclosure

The Company shall disclose the POSH Policy in the Annual Report and on its website, as required by applicable laws and regulations.

12. Conclusion

Vertotech Aerospace Ltd. is committed to providing a safe and respectful workplace where all employees can work without fear of harassment. This POSH Policy is designed to prevent, address, and resolve issues of sexual harassment and to uphold the highest standards of workplace conduct.

Date of Adoption: [Insert Date]

Approved by: Board of Directors, Vertotech Aerospace Ltd.