Table of Content

1. Commitment

Tristha Global Private Limited (“Company”) is committed to providing equal employment opportunities, i.e. no discrimination based on age, race, color, religion, national origin, or gender. All employees are entitled to a work environment free of sexual intimidation and one which promotes dignity, respect, and affordable equitable treatment, the Company ensures promoting a work environment that is conducive to the professional growth of all employees and encourages equal opportunity to all.

In this regard, the Company has framed this policy on Prevention and Redressal of Sexual Harassment (herein referred to as “Policy”). The Policy aims to prevent/prohibit and redress any incident of Sexual Harassment and to enforce strong disciplinary action in face of any such occurrence. The Policy defines Sexual Harassment and provides a framework to deal with complaints of Sexual Harassment at the Workplace or related to the workplace.

Tristha’s POSH policy is gender-neutral in nature and covers all employees without any regard to their gender. The Company is committed to providing a workplace free from sexual harassment for all employees. Complaints made by women shall be dealt with in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. Any form of Sexual Harassment whether overt or covert is unacceptable, and therefore regarded as misconduct as per the terms of this Policy. The Company will take action consistent with its disciplinary and grievance procedures against any employee found to have breached this Policy. The company will also take steps to comply with any specific domestic laws relating to this issue.

2. Objectives

1. Provide a work environment free from fear, reprisal, coercion, discrimination, and harassment of sexual nature.
2. Express zero tolerance to any Sexual Harassment at Workplace through Prevention, Resolution, and Deterrence of acts of Sexual Harassment.
3. Enable all those working, associated, and visiting the Company to raise their concerns and make complaints without any fear.
4. Define Sexual Harassment and provide a clearly stated codified redress for any Sexual Harassment occurring at Workplace.
5. Provide a procedure for the resolution, conciliation (where applicable), inquiry and redressal of complaints of Sexual Harassment.
6. Ensure a fair, impartial and timely inquiry and reach a reasonable decision in a timely manner.

3. Applicability

This Policy applies to all individuals who are employed in the Company, either engaged in permanent, contractual, or temporary capacity (whether in the office premises or in any office which includes regional / branch and any external location visited by the employees during the course of employment whether within or outside of India). This Policy also applies to the harassment of/by vendors, visitors, interns, apprentice, and customers of the Company depending on the merit of the case which affects the business interest of the Company.

4. Definition

Sexual Harassment means one or more unwelcome acts or behaviour involving unsolicited and unwelcome behavior (whether directly or by implication) towards a co-worker/subordinate/supervisors/third party personnel involving, but not limited to, any of the following:

1. Physical contact or unwelcome advances;
2. Demand or request for sexual favors;
3. Sexually colored remarks;
4. Showing pornography or displaying, circulating or sharing any sexually explicit or obscene material. This includes circulation/displaying of potentially offensive sexually oriented content in the Workplace;
5. Any other unwelcome physical, verbal or non-verbal conduct of sexual nature like jokes/comments/conversations causing or likely to cause awkwardness or embarrassment;
6. Innuendo and taunts of sexual nature;
7. Physical confinement against one’s will and likely to intrude upon one’s privacy; or sexual assault;
8. Sounds, gestures, staring, leering, gender-based insults or sexist remarks, sexual overtone in any manner such as over telephone/mobile, Email and includes any act or conduct by a person and belonging to one sex which denies or would deny equal opportunity in pursuit of employment/retention/career development or otherwise making the environment at the Workplace hostile, humiliating or intimidating to person belonging to the other sex;
9. Un-welcome propositions/requests for social dates/sexual activity.

The following circumstances among other circumstances, if it occurs or is present in relation to or connected with any act or behavior of Sexual Harassment may amount to Sexual Harassment:

1. Implied or explicit promise of preferential treatment in employment, or
2. Implied or explicit threat of detrimental treatment in employment, or
3. Implied or explicit threat about the present or future employment or
4. Humiliating treatment likely to affect the health or safety.

5. Responsibilities

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. Every employee shall maintain a work environment that is free from Sexual Harassment and shall immediately report any incident witnessed or experienced.

6. Complaints Committee

The Company has constituted an Internal Committee (IC) in accordance with the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, to receive, investigate and redress complaints of sexual harassment in a fair, impartial and time-bound manner.

Details of the Internal Committee, including the names and contact details of its members, shall be communicated to all employees through appropriate communication channels and displayed at conspicuous places at the workplace.

The Committee shall be responsible for:

1. Receiving complaints of sexual harassment.
2. Conducting inquiries in accordance with the provisions of the Act.
3. Maintaining strict confidentiality throughout the proceedings.
4. Recommending appropriate interim relief and disciplinary action, wherever applicable.
5. Submitting its findings and recommendations to the Employer within the prescribed timelines.
6. Preparing the Annual Report as required under the Act.

7. Procedures for Resolution, Settlement or Prosecution of Acts of Sexual Harassment

The Company is committed to providing a supportive environment to resolve concerns of sexual harassment as under:

A. Informal Resolution Options

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 the victim is not comfortable with addressing the harasser directly, the victim can bring their concern to the attention of the Internal Committee for redressal of their grievances. The Internal Committee will thereafter provide advice or extend support as requested and will undertake prompt investigation to resolve the matter.

B. Complaints

Any aggrieved woman may submit a written complaint to the Internal Committee within three months from the date of the incident or, in the case of a series of incidents, within three months from the date of the last incident. The Internal Committee may extend the time limit by a further period of three months if it is satisfied that circumstances prevented the complainant from filing the complaint within the prescribed period.

Before initiating an inquiry, the Internal Committee may, at the written request of the complainant, take steps to settle the matter through conciliation. No monetary settlement shall be made as the basis of conciliation.

During the pendency of the inquiry, the Internal Committee may recommend to the Employer appropriate interim relief, including transfer of either party, grant of leave to the complainant as permitted under the Act, change in reporting relationships, or any other suitable relief to ensure a fair and safe working environment.

The Internal Committee shall complete the inquiry within 90 days from the date of receipt of the complaint and submit its report to the Employer. The Employer shall act upon the recommendations of the Internal Committee within 60 days of receipt of the report. The Internal Committee shall prepare and submit an Annual Report containing the particulars prescribed under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, and the applicable Rules.

The victim can also seek legal remedies as may be available under the various laws for the time being in force.

The Committee shall keep complete documentation of the complaint, investigation and its report. The committee/officer designated for this purpose shall ensure that all documents shall also be kept securely in the personal files of the complainant as well as the person complained against.

The Company shall:

1. Provide a safe working environment.
2. Display the details of the Internal Committee and the penal consequences of sexual harassment at conspicuous places.
3. Organize regular awareness and sensitization programmes for employees and capacity-building programmes for the Internal Committee.
4. Assist the complainant in initiating legal proceedings wherever required.
5. Treat sexual harassment as misconduct under the Company’s service rules.
6. Implement the recommendations of the Internal Committee within the prescribed timelines.

8. 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 the investigatory process to the extent practicable and appropriate under the circumstances.

9. 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.

10. 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 the 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.

11. False or Frivolous or Malicious Complaints

If it is revealed at any stage of the investigation that the complaint made was false or frivolous or was made with malicious intent or with the motive of maligning the concerned individual or to settle personal professional scores, strict action will be taken against such complainant.

A mere inability to substantiate a complaint or provide adequate proof may not attract action against the complainant under this clause, unless circumstances suggest otherwise.

12. Awareness About Policy

Awareness about this Policy shall be created by displaying or notifying the salient features of the Policy in a suitable manner and Employees will be free to raise issues relating to Sexual Harassment and the same will be discussed in meetings with the management.

All steps should be taken by the Company to inform third party personnel having a business relationship with the Company about the existence and applicability of this Policy. This may include a display of this Policy at a conspicuous location.

13. Conclusion

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

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