Prevention of Sexual Harassment (POSH) Policy

2. Objectives

The objectives of this Policy are to:

• (a) prevent sexual harassment at the workplace;
• (b) provide a workplace based upon dignity, equality, mutual respect and professionalism;
• (c) prohibit every form of sexual harassment and inappropriate gender-based behaviour;
• (d) establish a legally compliant Internal Committee ("IC");
• (e) provide an accessible, confidential and fair complaint mechanism;
• (f) ensure prompt inquiry into complaints of sexual harassment;
• (g) protect complainants, witnesses and other participants against retaliation;
• (h) maintain confidentiality throughout the complaint and inquiry process;
• (i) provide appropriate interim relief wherever necessary;
• (j) promote awareness regarding rights and responsibilities under the POSH Act;
• (k) ensure compliance with all statutory obligations under the POSH Act, 2013 and applicable Rules;
• (l) encourage early reporting of incidents;
• (m) promote gender sensitivity and respectful workplace culture; and
• (n) safeguard the dignity, privacy and legitimate interests of every individual associated with the Company.

3. Scope and Applicability

This Policy shall apply to every woman employee as defined under the POSH Act and shall extend to all workplaces of the Company.

In addition, all persons associated with the Company are expected to comply with the standards of conduct prescribed herein. Accordingly, the behavioural obligations under this Policy shall apply to:

• Permanent Employees;
• Probationary Employees;
• Contractual Employees;
• Fixed-Term Employees;
• Temporary Employees;
• Interns (paid or unpaid);
• Apprentices;
• Trainees;
• Consultants;
• Advisors;
• Directors;
• Agency Personnel;
• Third-Party Service Providers;
• Vendors;
• Suppliers;
• Clients;
• Customers;
• Business Associates;
• Visitors; and
• Any other person present at or connected with the workplace.

The complaint redressal mechanism under the POSH Act shall operate in accordance with the statutory provisions applicable to an "Aggrieved Woman" as defined under the Act. Conduct by any individual, irrespective of gender, that violates the standards of workplace behaviour may also be addressed under other applicable Company policies, including the Code of Conduct and Zero Tolerance Policy.

4. Workplace

For the purpose of this Policy, "Workplace" shall have the widest possible meaning under Section 2(o) of the POSH Act and shall include, without limitation:

• (a) every office, branch, operational centre and administrative premises of the Company;
• (b) client offices;
• (c) business meetings;
• (d) conference rooms;
• (e) training programmes;
• (f) workshops;
• (g) seminars;
• (h) official events;
• (i) company-sponsored functions;
• (j) transportation provided by the Company;
• (k) work-related travel;
• (l) accommodation arranged during official travel;
• (m) virtual meetings;
• (n) online collaboration platforms;
• (o) work-from-home arrangements;
• (p) hybrid work locations;
• (q) official emails;
• (r) official messaging applications;
• (s) official telephone communications;
• (t) digital workspaces;
• (u) any place visited by an employee arising out of or during the course of employment; and
• (v) every location connected with Company business where interaction occurs because of employment.

5. Definitions

Unless the context otherwise requires:

5.1 Aggrieved Woman

"Aggrieved Woman" shall have the meaning assigned under Section 2(a) of the POSH Act and includes any woman, irrespective of age or employment status, who alleges that she has been subjected to sexual harassment at the workplace.

5.2 Respondent

A person against whom a complaint of sexual harassment has been made.

5.3 Complainant

The Aggrieved Woman who submits a complaint under this Policy.

5.4 Employee

"Employee" shall have the meaning assigned under Section 2(f) of the POSH Act and includes every person employed by the Company for any work on a regular, temporary, ad hoc, daily wage, contractual, trainee, apprentice, probationary or voluntary basis, whether directly or through an agent.

5.5 Internal Committee (IC)

The Internal Committee constituted by the Company under Section 4 of the POSH Act for receiving, inquiring into and recommending action regarding complaints of sexual harassment.

5.6 Sexual Harassment

"Sexual Harassment" shall have the meaning assigned under Section 2(n) read with Section 3 of the POSH Act.

5.7 Workplace

Workplace shall have the meaning assigned under Section 2(o) of the POSH Act and shall include every physical, virtual and work-related environment described under this Policy.

5.8 Employer

Employer shall have the meaning assigned under Section 2(g) of the POSH Act.

6. What Constitutes Sexual Harassment

Sexual Harassment includes one or more unwelcome acts or behaviour, whether directly or by implication.

Illustrative examples include:

• (a) physical contact and advances;
• (b) demand or request for sexual favours;
• (c) sexually coloured remarks;
• (d) showing pornography or sexually explicit material;
• (e) sending obscene emails, messages, GIFs, videos or photographs;
• (f) repeated unwelcome invitations for personal relationships or dates;
• (g) inappropriate touching;
• (h) unnecessary physical proximity;
• (i) sexually suggestive jokes;
• (j) unwelcome comments regarding appearance or body;
• (k) lewd gestures;
• (l) stalking;
• (m) repeated unwanted calls or messages;
• (n) sexually offensive social media behaviour;
• (o) inappropriate video calls;
• (p) displaying sexually offensive material in the workplace;
• (q) making employment decisions in exchange for sexual favours (quid pro quo);
• (r) creating a hostile, intimidating or offensive work environment through sexually inappropriate behaviour; and
• (s) any other conduct recognized as sexual harassment under the POSH Act or applicable law.

The above list is illustrative and not exhaustive.

7. Circumstances That May Constitute Sexual Harassment

Without prejudice to the provisions of the POSH Act, the following circumstances, among others, may amount to sexual harassment where connected with any unwelcome act or behaviour:

• (a) implied or explicit promise of preferential treatment;
• (b) implied or explicit threat of detrimental treatment;
• (c) threat regarding employment status;
• (d) interference with work performance;
• (e) humiliation likely to affect health or safety;
• (f) creation of an intimidating or hostile work environment;
• (g) repeated offensive conduct despite objection;
• (h) misuse of authority for obtaining personal or sexual favours; and
• (i) any conduct adversely affecting the dignity of the aggrieved woman.

8. Guiding Principles

Implementation of this Policy shall be governed by the following principles:

8.1 Dignity and Respect

Every individual shall be treated with dignity, equality and respect.

8.2 Zero Tolerance

The Company shall not tolerate sexual harassment in any form.

8.3 Natural Justice

Both the complainant and the respondent shall be provided a fair opportunity to present their case during the inquiry.

8.4 Confidentiality

All proceedings, records, evidence, witness statements and recommendations shall remain confidential in accordance with Section 16 of the POSH Act.

8.5 Timely Resolution

Complaints shall be dealt with promptly and in accordance with the timelines prescribed under the POSH Act and this Policy.

8.6 Non-Retaliation

No complainant, witness, Committee member or participant shall be subjected to retaliation, victimization or adverse employment action for participating in proceedings under this Policy.

8.7 Fair and Impartial Inquiry

Every complaint shall be investigated objectively, without bias, prejudice or conflict of interest.

8.8 Good Faith

Employees are encouraged to report genuine incidents honestly and responsibly. The inability to substantiate a complaint shall not, by itself, attract action against the complainant unless the complaint is found to be knowingly false or malicious in accordance with the POSH Act.

9. Rights and Responsibilities

Every employee has the responsibility to:

• maintain a respectful workplace;
• refrain from conduct amounting to sexual harassment;
• cooperate with the Internal Committee;
• maintain confidentiality;
• participate in awareness programmes;
• report incidents of sexual harassment in good faith; and
• comply with this Policy and applicable law.

Managers and supervisors shall additionally ensure that the workplace remains free from harassment and that complaints are immediately referred to the Internal Committee without delay.

10. Constitution of the Internal Committee (IC)

In accordance with Section 4 of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, the Company shall constitute an Internal Committee (IC) at every office or administrative unit where required under applicable law.

The Internal Committee shall function as an independent and impartial body responsible for receiving, examining and inquiring into complaints of Sexual Harassment made under this Policy.

The Committee shall discharge its duties with fairness, confidentiality, sensitivity and in accordance with the principles of natural justice.

11. Composition of the Internal Committee

The Internal Committee shall ordinarily consist of the following members:

(a) Presiding Officer

A woman employee employed at a senior level in the Company shall be nominated as the Presiding Officer.

In the absence of a senior-level woman employee, the Company may nominate a suitable woman employee from another office or administrative unit in accordance with the POSH Act.

(b) Internal Members

Not less than two (2) employee members shall be nominated from amongst employees who are:

• committed to the cause of women;
• experienced in social work;
• familiar with employment laws;
• knowledgeable in human resource management;
• experienced in compliance matters; or
• capable of conducting fair workplace inquiries.

(c) External Member

One External Member shall be nominated from amongst:

• a Non-Governmental Organisation (NGO);
• an association committed to women's rights;
• an advocate;
• a legal professional;
• a social worker; or
• any individual having experience relating to issues of sexual harassment or women's rights.

The External Member shall act independently and shall participate in all proceedings to ensure neutrality, fairness and statutory compliance.

(d) Gender Representation

At least one-half (½) of the total members of the Internal Committee shall be women, in accordance with the POSH Act.

12. Tenure of Members

The Presiding Officer and every Member of the Internal Committee shall ordinarily hold office for a period not exceeding three (3) years from the date of nomination, unless removed or replaced earlier in accordance with law or Company requirements.

The Company reserves the right to reconstitute the Committee whenever necessary to ensure statutory compliance.

13. Powers and Functions of the Internal Committee

The Internal Committee shall have the authority to:

• (a) receive complaints;
• (b) acknowledge complaints;
• (c) assist complainants in filing complaints where required;
• (d) conduct preliminary scrutiny;
• (e) recommend conciliation where legally permissible;
• (f) conduct formal inquiries;
• (g) summon parties;
• (h) examine witnesses;
• (i) inspect documents;
• (j) examine electronic evidence;
• (k) review CCTV footage;
• (l) review emails and official communications;
• (m) recommend interim relief;
• (n) recommend disciplinary action;
• (o) recommend compensation in accordance with the POSH Act;
• (p) recommend closure where allegations are not established;
• (q) submit inquiry reports to the Employer; and
• (r) perform every other function assigned under the POSH Act and applicable Rules.

14. Filing of Complaint

Any Aggrieved Woman who believes that she has been subjected to Sexual Harassment at the Workplace may submit a written complaint to the Internal Committee.

The complaint shall ordinarily contain:

• (a) name and designation of the complainant;
• (b) details of the respondent;
• (c) date, time and place of the incident;
• (d) description of the incident;
• (e) names of witnesses, if any;
• (f) supporting documents;
• (g) electronic evidence, if available; and
• (h) the relief sought.

Where the complainant is unable to submit a written complaint due to physical incapacity, mental incapacity or any other sufficient cause, the Internal Committee shall render all reasonable assistance in reducing the complaint into writing in accordance with the POSH Act.

15. Limitation Period

A complaint shall ordinarily be submitted within three (3) months from the date of the incident.

In the case of a series of incidents, the complaint shall ordinarily be submitted within three (3) months from the date of the last incident.

Where the Internal Committee is satisfied that circumstances prevented the complainant from filing the complaint within the prescribed period, it may extend the time for filing by a further period not exceeding three (3) months, after recording the reasons for such extension in writing, as provided under the POSH Act.

Upon receipt of the complaint, the Internal Committee shall endeavour to acknowledge the complaint and initiate the preliminary administrative process within thirty (30) days, without affecting the statutory timelines prescribed under the POSH Act.

16. Assistance in Filing Complaint

Where the Aggrieved Woman is unable to file the complaint personally due to physical incapacity, mental incapacity, death or any other circumstance recognised under the POSH Act, the complaint may be made by a person authorised under the Act, and the Internal Committee shall provide reasonable assistance to facilitate the filing and processing of the complaint.

17. Preliminary Scrutiny

Upon receipt of the complaint, the Internal Committee shall:

• (a) examine whether the complaint falls within its jurisdiction;
• (b) verify compliance with statutory requirements;
• (c) determine whether immediate interim measures are necessary;
• (d) preserve relevant evidence;
• (e) assign a confidential case reference number;
• (f) notify the respondent in accordance with law; and
• (g) proceed further in accordance with the POSH Act and this Policy.

The preliminary scrutiny shall not be construed as a determination of guilt or innocence.

18. Conciliation

Before initiating an inquiry, the Internal Committee may, at the written request of the Aggrieved Woman, attempt conciliation between the parties in accordance with Section 10 of the POSH Act.

Conciliation shall be voluntary and shall never be imposed upon the complainant.

No monetary settlement shall form the basis of conciliation.

Where conciliation is successfully concluded:

• (a) the terms of settlement shall be recorded in writing;
• (b) copies shall be provided to both parties and the Employer;
• (c) the Internal Committee shall forward its settlement recommendations to the Employer for implementation; and
• (d) no further inquiry shall ordinarily be conducted unless the settlement terms are breached.

Where conciliation fails or is not requested, the Internal Committee shall proceed with a formal inquiry.

19. Formal Inquiry Procedure

Where conciliation is not requested or is unsuccessful, the Internal Committee shall conduct a formal inquiry in accordance with the POSH Act, the applicable Service Rules (where any), and the principles of natural justice.

The inquiry shall ordinarily involve:

Stage 1 – Registration

• Registration of complaint.
• Assignment of confidential case number.
• Acknowledgement of receipt.

Stage 2 – Notice

A copy of the complaint shall be furnished to the respondent, who shall be required to submit a written response together with supporting documents within the time specified by the Internal Committee.

Stage 3 – Evidence Collection

The Internal Committee may examine:

• documentary evidence;
• electronic records;
• emails;
• CCTV footage;
• official chats;
• witness statements;
• photographs;
• audio or video recordings;
• digital communications; and
• any other relevant evidence.

Stage 4 – Personal Hearings

Separate hearings may be conducted for:

• complainant;
• respondent; and
• witnesses.

Cross-examination, if considered necessary, shall be conducted in a manner that preserves dignity and avoids intimidation.

Stage 5 – Evaluation

The Internal Committee shall evaluate:

• oral evidence;
• documentary evidence;
• electronic evidence;
• credibility of witnesses;
• consistency of statements;
• surrounding circumstances; and
• applicable legal provisions.

Stage 6 – Inquiry Report

Upon completion of the inquiry, the Committee shall prepare a reasoned report containing:

• summary of allegations;
• defence of the respondent;
• findings;
• reasons;
• conclusions; and
• recommendations.

20. Interim Relief Measures

During the pendency of the inquiry, and upon a written request by the Aggrieved Woman, the Internal Committee may recommend to the Employer one or more interim measures permissible under Section 12 of the POSH Act, including:

• (a) transfer of either party to another workplace or department;
• (b) grant of leave to the Aggrieved Woman, in addition to her regular leave entitlement, up to the extent permissible under the Act;
• (c) temporary modification of reporting relationships or work assignments;
• (d) restriction on direct interaction between the parties;
• (e) temporary work-from-home or remote work arrangements, where operationally feasible;
• (f) restriction of access to specific workplace areas, systems or facilities where necessary for safety or confidentiality;
• (g) preservation of documents, electronic records and other relevant evidence;
• (h) provision of counselling or employee assistance support, where available; and
• (i) referral of the matter to the Legal & Compliance Department for advice on statutory obligations, risk management or coordination with law enforcement or other competent authorities, where warranted.

The Employer shall consider and implement the recommendations of the Internal Committee in accordance with the POSH Act and applicable law.

21. Confidentiality

The Company shall maintain strict confidentiality in accordance with Section 16 of the POSH Act.

No person shall publish, communicate or disclose to the public, media or any unauthorized person:

• (a) the identity of the complainant;
• (b) the identity of the respondent;
• (c) names and particulars of witnesses;
• (d) complaint details;
• (e) evidence;
• (f) inquiry proceedings;
• (g) recommendations of the Internal Committee; or
• (h) action taken by the Employer,

except where disclosure is expressly permitted or required by law.

Any unauthorized disclosure shall invite disciplinary action in addition to any liability under applicable law.

22. Protection Against Retaliation

The Company strictly prohibits retaliation, victimization or adverse treatment against:

• the Aggrieved Woman;
• the respondent (pending inquiry);
• witnesses;
• Internal Committee members; or
• any person participating in the proceedings.

Retaliation includes, without limitation:

• (a) intimidation;
• (b) threats;
• (c) harassment;
• (d) unfair transfer;
• (e) denial of promotion;
• (f) discriminatory appraisal;
• (g) reduction of responsibilities;
• (h) adverse employment action;
• (i) social or professional isolation;
• (j) malicious rumours; or
• (k) any conduct intended to discourage participation in the inquiry.

Any act of retaliation shall be treated as a serious violation and may result in disciplinary action under the Company's Zero Tolerance Policy, Code of Conduct, and other applicable policies.

23. Inquiry Report

Upon completion of the inquiry, the Internal Committee shall prepare a reasoned Inquiry Report in accordance with Section 13 of the POSH Act.

The Inquiry Report shall ordinarily contain:

• (a) particulars of the complaint;
• (b) summary of allegations;
• (c) response of the respondent;
• (d) issues considered during the inquiry;
• (e) documentary, oral and electronic evidence examined;
• (f) statements of witnesses, where relevant;
• (g) findings on each allegation;
• (h) reasons supporting the findings;
• (i) conclusion of the Internal Committee; and
• (j) recommendations to the Employer.

The Internal Committee shall submit the Inquiry Report to the Employer within the period prescribed under the POSH Act and shall provide copies of the report to both the complainant and the respondent in accordance with applicable law.

24. Action by the Employer

Upon receipt of the Inquiry Report, the Employer shall consider the recommendations of the Internal Committee and take appropriate action in accordance with Section 13 of the POSH Act, applicable service rules and Company policies.

The Employer shall endeavour to implement the recommendations within the statutory timeline and maintain a record of the action taken.

Nothing contained in this Policy shall prevent the Employer from taking immediate administrative measures where necessary to ensure workplace safety, preserve evidence, maintain discipline or comply with legal obligations.

25. Disciplinary Action

Where the allegations are proved, the Employer may impose one or more disciplinary measures depending upon the nature, gravity, frequency and impact of the misconduct, subject to applicable law and service conditions.

Such measures may include:

• (a) written warning;
• (b) apology in writing;
• (c) counselling or behavioural correction programmes;
• (d) mandatory gender-sensitization training;
• (e) adverse remarks in service records, where permissible;
• (f) withholding of promotion;
• (g) withholding of increment or incentive, where legally permissible;
• (h) suspension from duty;
• (i) transfer to another department or location;
• (j) reassignment of reporting responsibilities;
• (k) deduction from salary towards compensation as recommended under the POSH Act, where applicable and legally permissible;
• (l) termination of employment;
• (m) discontinuation of contractual engagement;
• (n) blacklisting of vendors or consultants, where applicable;
• (o) reporting the matter to the appropriate statutory or law enforcement authority, where required; and
• (p) any other lawful action considered appropriate under applicable law and Company policies.

The disciplinary action shall be proportionate to the seriousness of the misconduct established during the inquiry.

26. Compensation

Where the Internal Committee recommends payment of compensation to the Aggrieved Woman under Section 15 of the POSH Act, the Employer shall determine the manner of recovery in accordance with the recommendations and applicable law.

While recommending compensation, the Internal Committee may consider factors including:

• (a) mental trauma, pain, suffering and emotional distress;
• (b) loss of career opportunity;
• (c) medical expenses incurred;
• (d) loss of income;
• (e) feasibility of payment in lump sum or instalments; and
• (f) any other factor recognised under the POSH Act.

Where the respondent fails to pay the compensation as directed, recovery may be undertaken in the manner prescribed under applicable law.

27. Appeal

Any person aggrieved by the recommendations made by the Internal Committee or the action taken by the Employer under this Policy may prefer an appeal before the appropriate authority in accordance with Section 18 of the POSH Act and other applicable laws.

The appeal shall be filed within the period prescribed under the applicable law governing such appeal.

Nothing contained in this Policy shall restrict the statutory right of appeal available to either party.

28. Duties of the Employer

The Employer shall:

• (a) provide a workplace free from sexual harassment;
• (b) constitute the Internal Committee in accordance with law;
• (c) display at conspicuous places the penal consequences of sexual harassment and details of the Internal Committee;
• (d) organise regular awareness and sensitisation programmes for employees;
• (e) conduct orientation programmes for Internal Committee members;
• (f) provide necessary facilities for conducting inquiries;
• (g) assist in securing the attendance of witnesses;
• (h) make available documents and information required for inquiry;
• (i) provide assistance where criminal proceedings are initiated;
• (j) treat sexual harassment as misconduct under applicable service rules;
• (k) monitor implementation of recommendations made by the Internal Committee;
• (l) maintain confidentiality of proceedings;
• (m) submit statutory reports wherever required under applicable law; and
• (n) comply with every obligation imposed under the POSH Act and other applicable laws.

29. Duties of Employees

Every employee shall:

• (a) maintain professional conduct at all times;
• (b) respect the dignity and privacy of colleagues;
• (c) refrain from any act amounting to sexual harassment;
• (d) cooperate with the Internal Committee during inquiries;
• (e) provide truthful information and evidence;
• (f) maintain confidentiality of proceedings;
• (g) participate in awareness programmes organised by the Company;
• (h) immediately report incidents of sexual harassment in good faith; and
• (i) comply with this Policy and applicable law.

Managers and supervisors shall additionally ensure that workplace concerns are promptly escalated to the Internal Committee and that no retaliatory conduct occurs within their teams.

30. Awareness, Orientation and Training Programmes

The Company recognises that prevention of sexual harassment requires continuous awareness and education.

Accordingly, the Company shall conduct periodic programmes including:

• (a) induction training for new employees;
• (b) annual POSH awareness sessions;
• (c) gender-sensitisation workshops;
• (d) behavioural ethics programmes;
• (e) leadership awareness programmes;
• (f) specialised orientation programmes for Internal Committee members;
• (g) e-learning modules;
• (h) awareness through emails, posters, handbooks and digital communication; and
• (i) any additional programme considered necessary by the Company.

Participation in mandatory POSH training programmes may form part of the employee's compliance obligations.

31. Records and Documentation

The Company shall maintain complete and secure records relating to:

• (a) complaints received;
• (b) inquiry proceedings;
• (c) notices issued;
• (d) evidence produced;
• (e) witness statements;
• (f) recommendations of the Internal Committee;
• (g) action taken by the Employer;
• (h) training programmes conducted;
• (i) awareness initiatives; and
• (j) Annual Reports required under applicable law.

All records shall be maintained securely and shall be accessible only to authorised persons.

32. Annual Report

The Internal Committee shall prepare an Annual Report containing such particulars as may be required under the POSH Act and the Rules framed thereunder.

Where required, the Employer shall include the relevant details relating to the number of complaints received, disposed of and pending in its statutory reports or filings as prescribed under applicable law.

33. Confidentiality of Records

Every person associated with the proceedings, including the complainant, respondent, witnesses, Internal Committee members, management representatives, legal advisors and employees, shall preserve strict confidentiality.

No person shall publish or disclose any information relating to:

• (a) the complaint;
• (b) the identity of the parties;
• (c) witness details;
• (d) inquiry proceedings;
• (e) recommendations;
• (f) action taken; or
• (g) any confidential record,

except where disclosure is authorised under law.

Violation of confidentiality obligations may result in disciplinary action and other consequences as provided under applicable law.

34. False or Malicious Complaints

If, after completion of the inquiry, the Internal Committee concludes that the complaint was made with malicious intent or that false evidence was knowingly produced, it may recommend action against the complainant in accordance with Section 14 of the POSH Act.

However, mere inability to substantiate a complaint or provide adequate proof shall not by itself attract action against the complainant.

The Internal Committee shall record reasons before recommending any action under this clause.

35. Relationship with Other Company Policies

This Policy shall be read harmoniously with the Company's:

• Code of Conduct;
• Employee Handbook;
• Zero Tolerance Policy;
• Employee Grievance Redressal Policy;
• Equal Opportunity Policy;
• Data Privacy Policy;
• Information Security Policy;
• Disciplinary Policy; and
• any other policy notified by the Company from time to time.

Where any conduct falls outside the scope of the POSH Act but constitutes misconduct, the Company may take action under the applicable internal policy.

36. Policy Review and Amendment

This Policy shall be reviewed periodically and may be amended, modified or updated by the Company to reflect amendments to the POSH Act, judicial pronouncements, regulatory requirements or organisational needs.

Any amendment shall become effective from the date notified by the Company unless otherwise specified.

37. Statutory Compliance

This Policy has been framed in accordance with the provisions of:

• The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013;
• The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013;
• Relevant provisions of the Bharatiya Nyaya Sanhita, 2023 (where applicable);
• Other applicable labour and employment laws; and
• Judicial precedents issued by competent courts from time to time.

The Company shall comply with all statutory obligations relating to prevention, prohibition and redressal of sexual harassment at the workplace.

38. Saving Clause

Nothing contained in this Policy shall:

• (a) restrict the statutory rights available to an Aggrieved Woman under the POSH Act or any other applicable law;
• (b) prevent the Employer from initiating disciplinary, civil or criminal proceedings where warranted;
• (c) affect the jurisdiction of any competent judicial, regulatory or statutory authority;
• (d) limit any obligation imposed upon the Employer under applicable law; or
• (e) prejudice the rights of either party available under law.

In the event of any inconsistency between this Policy and the provisions of the POSH Act or any other applicable legislation, the provisions of the applicable law shall prevail to the extent of such inconsistency, and the remaining provisions of this Policy shall continue to remain valid and enforceable.

39. Employee Acknowledgement

Every employee shall be deemed to have acknowledged and accepted this Policy upon its communication, publication on the Company's intranet, inclusion in the Employee Handbook, issuance through electronic means or execution of an acknowledgment form.

All employees are expected to comply with this Policy throughout their association with the Company and to contribute towards maintaining a safe, respectful and harassment-free workplace.