Anti-Sexual Harassment Policy


Company is committed to create a healthy working environment that enables employees to work without fear of prejudice, gender bias and sexual harassment.

Company regards sexual harassment and actions that create a hostile work environment as a very serious matter and such conduct is prohibited in the workplace by any person and in any form. Company also believes that all employees of the Company have to be treated with dignity.


  • Extends to all employees of the Company and is deemed to be incorporated in the service conditions of all employees and comes into effect immediately.
  • Applicable at all locations and activities including those run in partnership so also to all company-sponsored social events.
  • Applies to men and women; to like and opposite gender relationships; to relationships between supervisors and subordinates; doctors and patients; and peer relationships. It includes employees, customers, vendors, consultants, and anyone else doing business on our premises, as well as to those involved in activities in which our name is associated.
  • All associates shall comply with this policy.


Employee includes a person employed / engaged by the company for any work directly, or by or through any Agency.

  • For this purpose, “Sexual Harassment" includes any unwanted or unwarranted gesture or verbal sexual advances, sexually explicit and derogatory statements or remarks, sexually colored remarks, avoidable and unwarranted physical contacts, willfully touching or patting, suggestive sexual remarks, sexually slanted and obscene jokes, vulgar comments about physical appearance, indecent invitations, stalking sounds, lurid stares, use/ showing of pornographic material, display of pictures, demand for sexual favors, demanding sexual favor by making telephone calls or sending SMS/Mails, threats of physical assault or molestation on refusal by the employee by their superiors, colleagues or anyone who for the time being is in a position to sexually exploit or harass the employee at any work place which may contain :
  • Implied or overt promise of preferential treatment in that employee’s employment
  • An implied or overt threat of detrimental treatment in that employee’s employment or an implied or overt threat about the present or future employment status of that employee and includes the creation of a hostile working environment.
  • The conduct interferes with an employee's work or creates an intimidating, hostile or offensive work environment.
  •   Such conduct that is humiliating and may constitute a health and safety problem which offends the individuals sensibilities and affect her/his performance;
  • Conduct of such an act at work place or outside in relation to an Employee, or vice versa during the course of employment;


CASH has been constituted to consider and redress complaints of Sexual Harassment. The committee should be headed by a Woman and Woman members should not be less than half of the total members in the committee who are direct employees of the Company

HR Department shall finalize the Committee members in coordination with respective Works / Site / Branch / Location Head and shall circulate Committee details to employees in respective locations. The size of the Committee shall not be more than 5 members.


  • Tell the harasser his/her behavior is unwelcome and ask him/her to stop.
  • Keep a record of incidents (date, time, locations, possible witnesses, what happened, your response). You do not have to have a record of events in order to file a complaint, but a record can strengthen your case & help you remember details over


  • Employee has to submit his / her compliant in writing on the occurrence of such an incident at their respective location mentioning the Date and nature of the harassment.
  • Upon receipt of the formal complaint from the employee CASH Committee will initiate investigation on the veracity / strength of the compliant. Confidentiality will be maintained during the investigation.
  • Organization will not tolerate any form of reprisal or retaliation against an employee or applicant reporting any incident of claimed sexual harassment. 
  • False accusations of harassment will not be tolerated and would be viewed seriously.


  • A quorum of 3 members is required to start the Enquiry process
  • If the complaint is raised against a Committee member by the Complainant, the Committee shall ensure that the defendant should not be the part of the Committee and not allowed to be part of the proceedings / interfere in the proceedings.
  • CASH Committee shall maintain a register to endorse the complaint received. The details are to be recorded and maintained.
  • The CASH Committee members shall hear the Complainant and record his/her allegations. The Complainant / defendant can submit any corroborative material with a documentary proof, written material, etc., in original which is self attested to substantiate his / her complaint. If the Complainant (if Female) does not wish to depose personally due to embarrassment of narration of event, a female co-employee shall meet and record the statement.
  • Thereafter, the defendant shall be called for a deposition before the Committee and an opportunity will be given to him/ her to give an explanation, where after, an “Enquiry” shall be conducted and concluded.
  • In case the complaint is proved true, HR Department shall initiate necessary action as recommended by the CASH Committee.
  • In the event, the complaint does not fall under the purview of Sexual Harassment; the same would be dropped after recording the reasons there of.
  • CASH Committee shall complete the “Enquiry” within 60 days from the date of complaint and communicate its findings and its recommendations for action to the HR Department
  • Where sexual harassment occurs as a result of an act or omission by any third party or outsider, CASH committee shall take steps necessary and reasonable to assist the affected person in terms of support and preventive action.
  • In case the Committee finds the degree of offence coverable under the Indian Penal Code, then this fact shall be mentioned in its report and appropriate action shall be initiated by the Management, for making a Police Complaint.


This policy shall not be used to bring frivolous or malicious complaints against anyone. Making a knowingly false complaint subjects the complaint to disciplinary or corrective action. However, failure to prove a claim of sexual harassment does not constitute proof of a false and / or malicious accusation.


  • No person shall be victimized for anything said or done in relation to any complaint.
  • A person victimizes another person if the person subjects the other person or threatens to subject the other person to any detriment in connection with employment or recruitment or promotion because such person
  • Has brought proceedings against any person.
  • The other person associates with the complainant.
  • Has given evidence or information or produced a document, in connection with any proceedings.


CASH Committee shall take all reasonable steps to ensure prevention of sexual harassment at work. Such steps shall include:

  • Circulation of the policy in English/ Vernacular in Office / Plant / Works locations on Sexual harassment to all direct / indirect employees.
  • Sexual harassment will be affirmatively discussed at monthly meetings, workshops etc.,
  • Conduct regular in-house training on sexual harassment and addressing complaints to all direct / indirect employees.
  • Guidelines will be prominently displayed to create awareness of the rights of female employees.
  • A commitment is required from all the levels of the organization for the positive implementation of the policies and procedures made against sexual harassment.
  • Widely publicize that the Sexual Harassment is a crime & will not be tolerated.
  • Names and contact numbers of members of the CASH committee will be prominently displayed in all the Offices/ Projects.


Source Stop the Harassing Behaviour
Target Tell the source to stop and/or report the behaviour.
Observer No such thing as an innocent bystander
Person A Duty Exists


Finally, CASH Committee shall affirmatively follow up with the complainant after one month of decision to determine

  • Whether the inappropriate activity has stopped
  • Whether any retaliatory or related activity has been initiated against the complainant by the defendant
  • Depending on the situation, it may also be advisable to interview coworkers or supervisors of the harasser in order to ascertain whether inappropriate activity has continued with respect to the original victim or other parties.


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


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.


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 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.


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