Prevention of Sexual Harassment (POSH) Policy

1. Purpose:

The purpose of this policy is to provide a safe, respectful, and inclusive workplace by preventing, prohibiting, and addressing incidents of sexual harassment in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act, 2013.

2. Scope:

This policy applies to all employees (permanent, temporary, contractual, and interns) of Sunbeam Elastomers Pvt. Ltd., as well as vendors, clients, and visitors associated with the company.

3. Definition of Sexual Harassment:

Sexual harassment includes any unwelcome behavior of a sexual nature, such as:

• (a) Physical contact or advances.
• (b) Demand or request for sexual favours.
• (c) Making sexually coloured remarks.
• (d) Showing pornography.
• (e) Any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature.

4. Objectives:

• (a) To create a workplace free from sexual harassment.
• (b) To establish a mechanism for the prevention and redressal of complaints.
• (c) To comply with the legal requirements under the POSH Act, 2013.

5. Policy Guidelines:

Internal Complaints Committee (ICC):

The company shall constitute an Internal Complaints Committee (ICC) with the following members:

• (a) A presiding officer (a senior female employee).
• (b) At least two employees with a commitment to addressing issues of harassment.
• (c) One external member from an NGO or legal background.

The ICC will:

• (a) Receive and address complaints of sexual harassment.
• (b) Conduct impartial inquiries and recommend actions.
• (c) Submit annual reports to the employer and local authority.

Complaint Procedure:

• (a) Complaints should be made in writing and submitted to the ICC within 3 months of the incident.
• (b) If the complainant cannot write, the ICC will assist in documenting the complaint.

Inquiry Process:

• (a) The ICC will initiate an inquiry within 7 working days of receiving a complaint.
• (b) The inquiry will be completed within 90 days, and findings will be submitted to the employer.
• (c) Based on the ICC’s recommendations, appropriate action will be taken within 60 days.

6. Confidentiality:

• (a) The identity of the complainant, respondent, and witnesses, as well as any details of the case, will remain confidential.
• (b) Breach of confidentiality will result in disciplinary action.

7. Prohibition of Retaliation:

• (a) Retaliation against the complainant, witnesses, or ICC members is strictly prohibited.
• (b) Disciplinary action will be taken against anyone attempting to intimidate or victimize involved parties.

8. Disciplinary Action:

1. If the ICC finds the complaint valid, the company may impose penalties, including:

• (a) Verbal or written warning.
• (b) Suspension or termination of employment.
• (c) Deduction of compensation as a fine to the complainant.

2. False complaints or malicious accusations will also result in disciplinary action.

9. Awareness and Training:

• (a) Regular training and awareness sessions on the POSH Act and policy will be conducted for employees.
• (b) Posters and materials outlining the policy and complaint process will be displayed in prominent areas of the workplace.

10. Monitoring and Reporting:

1. The ICC will submit an annual report summarizing:

• (a) Number of complaints received and resolved.
• (b) Nature of actions taken.

2. The report will be shared with the local authority, as required under the POSH Act.

11. Review and Amendments:

This policy will be reviewed annually to ensure compliance with statutory requirements and workplace needs. Amendments will be recommended by the ICC and approved by the management.

Approval:

This POSH Policy has been approved by the Board of Directors of Sunbeam Elastomers Pvt. Ltd. on 1st January 2025.

This policy ensures a robust framework for addressing sexual harassment at Sunbeam Elastomers Pvt. Ltd.