• This Policy is applicable to all employees of the Company at all levels, including full-time, part- time, contractual, temporary, trainees, interns and apprentices. The Policy also covers third parties such as vendors, service providers, consultants, contractors, customers, clients, visitors, guests and any other persons who may be present at the workplace or engaged in any work-related interaction, whether on Company premises, client locations, offsite locations, virtual platforms or during any official travel or events.
• Sexual harassment includes any one or more of the following unwelcome acts or behaviour (whether directly or by implication):
• Physical contact and advances.
• Demand or request for sexual favours.
• Making sexually coloured remarks.
• Showing pornography.
• Any other unwelcome physical, verbal or non-verbal conduct of sexual nature.
• Circumstances amounting to Sexual Harassment,
  The following circumstances, among others, if they occur in relation to sexual harassment, may amount to sexual harassment:
• Implied or explicit promise of preferential treatment.
• Implied or explicit threat of detrimental treatment.
• Threat about employment status.
• Hostile or offensive work environment.
• Humiliating treatment affecting health or safety.
• Gender Coverage under Law
  While this Policy applies to all employees, interns, trainees, consultants and third parties irrespective of gender, it is clarified that statutory protection under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 is available only to women.
  Complaints received from persons other than women shall be addressed under the Company’s internal disciplinary and grievance redressal mechanisms.
• Complaints Involving Third Parties (Visitors / Vendors / Clients)
  In case of sexual harassment by or against a third party such as vendors, contractors, consultants, customers, clients or visitors, the Company shall take appropriate action including, but not limited to, issuing warnings, restricting entry, terminating business relationship, blacklisting the concerned party, or reporting the matter to the relevant employer or authority, as deemed appropriate.
  The Company shall also provide reasonable assistance to the aggrieved person in pursuing the complaint with the concerned organization or authority.

• A Committee has been constituted by the Management to consider and redress complaints of Sexual Harassment. Management referred as Board of Directors and CEO.
• A quorum of 3 members is required to be present for the proceedings to take place. The quorum shall include the Chairperson / Presiding, at least two members. Out of that 50% and above should be ladies in ICC.
The committee will be responsible for:
• Receiving complaints of sexual harassment at the workplace.
• Initiating and conducting inquiry as per the established procedure.
• Submitting findings and recommendations of inquiries.
• Coordinating with the management in implementing appropriate action.
• Maintaining strict confidentiality throughout the process as per established guidelines.
• Submitting annual reports in the prescribed format.
• The External Member is independent and does not have any conflict of interest or business association with the Company.
• The ICC shall submit an annual report to the District Officer in the prescribed format as required under the POSH Act, 2013.

• Any employee who feels and is being sexually harassed directly or indirectly may submit a complaint of the alleged incident to any member of the Committee in writing with his/her signature within 3 months of occurrence of incident.
• The Committee will maintain a register to endorse the complaint received by it and shall be kept confidential at all times, except to use the same for discreet investigation.
• Conciliation: Before initiating an inquiry, the Internal Complaints Committee may, at the request of the aggrieved woman, take steps to settle the matter between the aggrieved woman and the respondent through conciliation, provided that no monetary settlement shall be made as a basis of conciliation.
  Where a settlement has been arrived at, the ICC shall record the same and forward it to the employer for compliance. Copies of the settlement shall be provided to both parties. Where the terms of settlement are not complied with by the respondent, the ICC shall proceed to conduct a formal inquiry.
• The Committee will hold a meeting with the Complainant within two days of the receipt of the complaint, but no later than a week in any case.
• At the first meeting, the Committee members shall hear the Complainant and record her/his allegations. The Complainant can also submit any corroborative material with a documentary proof, oral or written material, including eye witnesses, to substantiate his / her complaint. If the Complainant does not wish to depose personally due to embarrassment of narration of event, a female ICC member for female employees involved and a male ICC member for male employees, involved shall meet and record the statement.
• Thereafter, the person against whom complaint is made may be called for a deposition before the Committee and an opportunity will be given to him / her to give an explanation, where after, an “Inquiry” shall be conducted and concluded.
• INTERIM RELIEF
  During the pendency of the inquiry, on a written request made by the aggrieved person, the Internal Complaints Committee may recommend to the employer any of the following interim measures:
• Transfer of the aggrieved person or the respondent to any other workplace or department.
• Grant of leave to the aggrieved person for a period up to three (3) months, in addition to the leave to which she/he is otherwise entitled.
• Restriction on the respondent from reporting on the work performance of the aggrieved person or from having any direct or indirect contact with the aggrieved person.
• Any other relief as may be considered appropriate by the ICC to ensure a fair and safe working environment during the inquiry.
• 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.
• Action for false or malicious complaint shall be taken only where malicious intent is established after inquiry. Mere inability to substantiate a complaint shall not attract any action.
• TIME LIMITS
  The following statutory timelines shall be followed in handling complaints under this Policy:
• The complaint shall be filed within three (3) months from the date of occurrence of the incident.
• The Internal Complaints Committee shall complete the inquiry within ninety (90) days from the date of receipt of the complaint.
• The ICC shall submit its inquiry report to the employer within ten (10) days of completion of the inquiry.
• The employer shall act upon the recommendations of the ICC within sixty (60) days of receipt of the report.
• Any appeal shall be filed within ninety (90) days from the date of communication of the ICC recommendations.

• The Committee shall immediately proceed with the Inquiry and communicate the same to the Complainant and person against whom complaint is made.
• The Committee shall prepare and hand over the Statement of Allegation to the person against whom complaint is made and give him / her an opportunity to submit a written explanation if she / he so desires within 7 days of receipt of the same.
• The Complainant shall be provided with a copy of the written explanation submitted by the person against whom complaint is made.
• If the Complainant or the person against whom complaint is made desires any witness to be called, they shall communicate in writing to the Committee the names of witness whom they propose to call.
• 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 person against whom complaint is made 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.
• The Committee shall call upon all witnesses mentioned by both the parties.
• The Committee shall provide every reasonable opportunity to the Complainant and to the person against whom complaint is made, for putting forward and defending their respective case.
• The Committee shall complete the inquiry within a period of 90 days from the date of receipt of the complaint and submit its report to the employer within 10 days of completion of the inquiry. The report of the committee shall be treated as an Inquiry report on the basis of which the employee concerned can be awarded appropriate punishment straightaway.
• The Directors will direct appropriate action in accordance with the recommendation proposed by the Committee.
• The Committee shall be governed by the provisions of the POSH Act, 2013 and Rules framed thereunder.

• The committee shall on completion of the Inquiry provide a report of its findings within 10 days from the date of completion of the Inquiry and such report shall be made available to the concerned parties.
• If the allegation against the respondent has not been proved, the committee may recommend that no action needs to be taken in the matter.
• If the Internal Complaints Committee arrives at the conclusion that the allegation against the respondent has been proved, it shall recommend to:
• Take the action for sexual harassment as a misconduct.
• To tender written apology to the complainant, issue warning, withholding of promotions / increments of the Respondent, suspension / terminating the Respondent.
• Such action will be taken within 60 days of the receipt of report.

• Any person aggrieved by the recommendations of the Internal Complaints Committee may prefer an appeal to the appropriate authority or court, in accordance with the applicable service rules or law, within a period of 90 days from the date of communication of the recommendations of the ICC.

• The contents of the complaint, the identity and addresses of the aggrieved woman, respondent and witnesses, any information relating to conciliation or inquiry proceedings, recommendations of the ICC and action taken by the employer shall not be published, communicated or made known to the public, press or media in any manner.
  Any person who breaches confidentiality shall be liable for disciplinary action in accordance with the service rules of the Company and penalty as prescribed under the POSH Act, 2013.

• The Company strictly prohibits any form of retaliation against the aggrieved woman, respondent, witnesses, or any person who has participated in the complaint or inquiry process in good faith. Retaliation includes, but is not limited to, termination, demotion, denial of promotion, salary reduction, adverse performance evaluation, transfer, intimidation, harassment, or any other unfair treatment.
  Any employee found to have engaged in retaliation shall be subject to disciplinary action in accordance with the Company’s service rules.

• All Employees and Visitors shall have access to this policy at any given point of time and clarification related to this policy shall be addressed by the HR Team.
• A brief shall be given to all existing employees regarding the features of this policy immediately on formulation of the policy and to new employees in SANDS during their initial induction.
• The company shall comply with all other details as set out under section 19 of the Act to ensure that all employees are provided with the safe working environment at the workplace.
• Company shall display the notice showing the name of the Internal Complaints Committee members at its every establishment at a conspicuous place.

• The Company recognizes that a complaint of sexual harassment is a serious matter and shall be dealt with utmost sensitivity and confidentiality.
• If the Internal Complaints Committee arrives at a conclusion that the allegation was made with malicious intent, or that the aggrieved person or any other person making the complaint on behalf of the aggrieved person has knowingly produced false, forged or misleading evidence, the ICC may recommend appropriate action to be taken against such person in accordance with the service rules of the Company.
• However, mere inability to substantiate a complaint or provide adequate proof shall not attract any action under this clause.
• A similar recommendation for action may be made against any witness who is found by the ICC to have given false evidence or produced forged or misleading documents.
  This provision is not intended to discourage employees from raising genuine complaints and shall be applied strictly in cases where malicious intent is clearly established after due inquiry.

• The Committee may recommend to the Directors action which may include transfer / suspension/ termination or any of the other appropriate disciplinary action.
• The Management shall provide all necessary assistance for the purpose of ensuring full, effective and speedy implementation of this policy.
• Where sexual harassment occurs as a result of an act or omission by any third party or outsider, SANDS shall take all steps necessary and reasonable to assist the affected person in terms of support and preventive action.
• The Committee shall analyze and put up report on all complaints of this nature at the end of the year for submission to Directors.
• Where the ICC concludes that the conduct amounts to an offence under the Indian Penal Code (IPC), the ICC shall inform the aggrieved woman of her right to file a complaint with the appropriate authorities. The Company shall provide reasonable assistance to the aggrieved woman, if she chooses to do so.
• All procedures shall be followed strictly in accordance with the provisions of the POSH Act, 2013 and the Rules framed thereunder.
• The Company may make any alteration or amendment or rescind any of the clauses of this Policy as and when it finds it necessary to do so as it complies with Act. Any such alterations or amendment or rescinding will be intimated to the employee.
• Nothing contained in these rules shall operate in derogation of any law for the time being in force or to the prejudice of any employee under any other Rules or Law.

INTERNAL COMMITTEE (ICC)