Mulamoottil Group

Anti-Sexual Harassment Policy
Women Employment Safety and Security Policy

Anti-Sexual Harassment Policy

OBJECTIVE

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.

SCOPE AND EFFECTIVE DATE

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.

DEFINITIONS

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;

COMMITTEE AGAINST SEXUAL HARASSMENT (“CASH”)

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.

IF YOU ARE BEING HARASSED

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

PROCEDURE FOR REPORTING HARASSMENT

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.

ENQUIRY PROCESS

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.

IMPROPER COMPLAINTS

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.

PROHIBITION OF VICTIMISATION

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.

PREVENTIVE STEPS

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.

WHO SHOULD HELP STOP WORKPLACE HARASSMENT?

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

FOLLOW-UP WITH THE COMPLAINANT

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.

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

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.

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 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.

CONCLUSION

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.

Women Employment Safety and Security Policy

In the wake of increasing incidents of violence and atrocities against women, Following are the procedures developed to ensure safety of women in our society and in our work places.

The suggested guidelines for the safety for women at the workplace are broadly categorized under four heads:

1. Physical
2. Environmental
3. Organizational
4. Educational

Each of the above heads has procedural requirements and future recommendations.

Physical

This focuses on the physical security of women employees in an organization. It ascertains the safety of female employees, whilst they are on the job/ inside office premises – the workplace needs to be secure and women assured of basic safety on the job and in office.

Procedural Requirements

Identification documents (driving license, photo ID, address proof, Finger prints) to be collected from drivers, security guards and all casual staff
24x7 operational CCTV (Closed Circuit Television) cameras at vital locations or places, such as entry/ exit, common passages, etc in the factories and industries. However, this should not impinge the modesty and privacy of the employees
Where CCTV is not possible, manned entries/ gates and security deployment at the site/ office/ location 24x7 or depending upon the kind of working hours

Future Recommendations

Installation of electronic doors allowing access to the work area only to authorized employees / staff
High security fencing to discourage human trespassing in factory/office premises or campuses
Security guard or a colleague to accompany the driver in the cab, if a woman staff working in a night shift is either the first to be picked up or last to be dropped
GPS based monitoring of cabs/transport vehicles with panic buttons
SMS Alerts / Information Systems to be designed/installed
A thorough risk assessment of the neighboring area is recommended to ascertain that stringent measures are in place to mitigate any security risk
Mobile Applications to be installed on employee phones for increased tracking and safety measures

Environmental

The environmental aspect complements the physical aspect of security and helps maintain a safe and secure standard in any premises. This plays a vital role in ensuring the basic yet critical aspects of safety of employees.

Procedural Requirements

Clearly displayed emergency contact numbers and a designated officer(s) available round the clock to be contacted in emergency
Well lit work areas, staircases and parking lots till the last woman employee leaves the site
Separate and secure toilets for women close to their work station
Strict surveillance of visitors. Details of all the visitors such as name, organization, address, purpose of visit, person visited, time in and time out to be recorded in a register. This should apply not only to the visitors coming for business purposes but also to courier staff, delivery boys etc
Provision of company transport for women working in night shifts both to and from the workplace
Hiring of cabs/ transport vehicles on a regular basis only from established agencies

Future Recommendations

Security staff and drivers to be employed only after police verification or to be recruited from reputed agencies that have such measures in place
Compliance and Audits / Random Checks / Patrolling to be done periodically including breath analysis of cab drivers
24x7 transport helpdesk for drivers & staff / family members with dedicated emergency cab on standby for exigencies
Emergency Response Systems to record and support any emergencies across group of employees
Tracking of Ad-Hoc and No-Show staff transport users to drive more discipline in transport usage

Organizational

It is for the employer to create a positive atmosphere at the workplace where a woman is encouraged to come to work, secure in the knowledge that she will be treated with dignity, respect and will be protected from harassment.

Procedural Requirements

At the time of orientation, women in organizations to be made aware of their rights, facilities and actions that they can initiate regarding sexual harassment
To have a Code of Conduct agreement in place - to be affirmed annually by employees and vendors with clear defining behavioral norms especially for males with female employees
Internal compliance measurement on the awareness of the policy
Payment of salaries directly into bank accounts to avoid any kind of harassment by supervisory staff over subordinate women employees/casual women employees
Setting up of a sexual harassment committee reporting to the Managing Director or a senior member of the management and headed by a woman
Strict disciplinary action against those found violating the code of conduct to ensure that it is not repeated
The majority or at least two women to be on the committee, one from the staff and one from management
Every office to have a representative reporting to the committee
Every complaint verbal or written to be documented and investigated promptly by the committee and appropriate action must be taken irrespective of the person being a senior, supervisor, colleague, staff, customer or vendor
Women employees to be assured of speedy redressal, confidentiality of their complaints and protection from reprisal

Future Recommendations

Employee Feedback and Action on Company transport via Emails

Educational Aspect

The awareness of women employees of their company policies on sexual harassment and gender discrimination and the more they are encouraged to report all instances of discrimination without fear, the greater would be their feeling of security and empowerment.

Procedural Requirements

Awareness and training on security and safety. Dos & Don’ts while traveling by company cabs, Emergency contacts, Police help lines, company contact points
Awareness of the company policy on sexual harassment, on gender discrimination or gender biased approach and the complaint process
Regular reminders of the ethical values of the company, through emails, posters, sessions, etc
Provide training to all women employees and educate them about their rights and facilities
Training / Informing male employees through training sessions on what is expected out of them.
Training of all women staff on staying alert and being better prepared
Training of supervisors and other staff on how to respond to complaints of sexual harassment/gender discrimination

Future Recommendations

Self-defense classes to be organized at the workplace or sponsored by the organization
Posters advocating gender sensitivity to be displayed prominently
All organizations to have a system in place to monitor their activities on gender sensitization and security and safety issues
On-line basic security awareness training where women employees are guided on how to act when faced with sexual harassment
Drivers Training on Safety and etiquettes done twice a year with a special focus on mindset /behavioral change