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The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013

Anti-Sexual Harassment Policy:

Statement of philosophy

The Company does not tolerate workplace sexual harassment/discrimination. Such conduct violates an individual's fundamental rights and personal dignity and undermines the Company’s commitment to ensure freedom from such behavior in all aspects of employment. The Company considers sexual harassment/discrimination in all its forms to be a serious offence. This Policy is framed keeping in mind the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and Rules made thereunder ("Act and Rules")

Internal Complaints Commitee (ICC)

This committee is constituted to receive complaints on sexual harassment at the workplace from an aggrieved Noodler, as well as to inquire into and make recommendations to the employer on the action required pursuant to its inquiry of such complaint made.


Committee Members

Meghavarshini MG | HR Leader - India - Presiding Officer | | +91-9916942221

Ankita Ghosh | Senior Talent Acquisition Specialist | Committee Member | | +91-9986504875

Nayana Ravishankar | Director – Customer Success Management | Committee Member | | +91-9889316503

Kunal Kumar | Director – Data Science | Committee Member | | +91-9880755298

Gaurav Dalan | Finance Controller | Committee Member | | +91-9141089710

Martha McGaw | Chief Talent Officer | Committee Member |

Karuna SG | External Member | Lawyer | +91-9743017224

Sexual harassment definition:

Sexual harassment is defined as unwanted sexual attention of a persistent or offensive in nature from another person. This can be defined as unwelcomed sexual conduct (direct or implied) such as physical contact and advances, demand or requests for sexual favors, sexually colored remarks, showing pornography, creating a hostile work environment and any other sexually determined behavior (visual or physical or verbal acts) of a sexual or gender-based nature. It can be deemed to include sexually oriented conduct that is sufficiently pervasive or severe to unreasonably interfere with a Noodler's job performance or create an intimidating, hostile, or offensive working environment, as well as sexual harassment by tangible employment action (a.k.a. quid pro quo) where a Noodler is pressured to comply with a sexually oriented request as a basis for employment decisions.

Sexual harassment can be physical and/or psychological in nature. An accumulation of multiple minor incidents can constitute sexual harassment even if one of the incidents considered on its own would not qualify as ‘sexual harassment’ in terms hereof. Noodlers are prohibited from harassing other Noodlers whether the incidents of harassment occur on Company premises and whether or not the incidents occur during working hours.

Sexual harassment can involve males or females being harassed by members of either sex. All Noodlers are governed by the Company’s policy against sexual harassment regardless of whether a supervisor/subordinate relationship exists between the harasser and the harassed. Any person in the workplace is prohibited from engaging in prohibited harassment including third parties (non-Noodlers) present in the workplace, such as contract employees, customers or vendors/ suppliers or sub-contractors or interns/ trainees who interact with Noodlers and shall apply to all instances of Harassment which: (i) occurs between or among Noodlers and non-Noodlers (ii) arise due to a complaint by a third party against a Noodler or non-Noodler and where such person was or is involved in an activity pertaining to the company; and (iii) to the extent permitted by law or the policies of another entity, arises when a Noodler is sent to such another entity on behalf of, or for any activity related to the company. Anyone who believes that he or she has been subjected to such Harassment (“Victim”) is encouraged to report the problem using the procedures set forth in this Policy. The company will investigate a reported incident to the extent required by applicable law and will take remedial action where necessary.

Workplace definition:

Any place where a Noodler is in the course of Company’s work, including but not limited to:

a. Company premises

b. Vendor/customer place

c. Another unit of Company

d. Team outings/retreat organized by the Company

e. The company provided transport.

f. Work from home – virtual business meetings, virtual workspace.

Our policy is not intended to discourage healthy working relationships, good morale, team building and Company unity. However, certain conduct and comments of a sexual nature that may not amount to unlawful sexual harassment would still be considered inappropriate in the workplace. We expect our Noodlers to use good judgment always and avoid even the appearance of sexual impropriety in all their relationships with other Noodlers.

Examples of sexual harassment can include the following behaviors:

  • Promising or denying, directly or indirectly, a Noodler a reward or employment opportunity or penalty, based on a Noodler’s response to a sexually oriented request.

  • Threatening, directly or indirectly, to retaliate against a Noodler, if the Noodler refuses to comply with a sexually oriented request.

  • Engaging in sexually suggestive physical contact, gestures or touching.

  • Displaying/communicating sexually themed jokes, taunts, drawings/writings, cartoons, posters.

  • Displaying/using sexual or other gender related epithets, slurs, slang terms or profanity.

  • Displaying, storing, or transmitting pornographic or sexually oriented materials using Company equipment/ network or in the workplace.

  • Comments or references to parts of a person’s anatomy.

  • Engaging in indecent exposure or displaying images of nude or scantily clad persons.

PLEASE NOTE: This list is not intended, and nor should it be considered to include all behaviors that may be considered sexual harassment.

Reporting & Complaint Procedure

  1. If any Noodler experiences any sexual harassment at workplace, that person is required to report the matter to any member of the ICC* (Internal Complaints Committee) team or write an email to Persons wishing to report a complaint are encouraged (but not required) to do so via a written statement of events/concerns to facilitate a thorough investigation. All concerns reported in good faith will be taken seriously.

  2. In the event a complaint is reported in writing, the following complaint redressal process shall be followed. In the event a written complaint is not received, the ICC shall use its discretionary power to entertain and resolve such complaint/s as it deems fit and proper.

  3. A complaint must be reported to ICC within a maximum period of 3 (three) months from the date of the alleged incident and in case of a series of incidents, within a period of 3 (three) months from the date of last incident. along with the supporting documents and the names and addresses of the witnesses, if any. The Committee may extend the time limit by another 3 months at its discretion. Committee may also provide assistance to a victim to write the Complaint.

  4. Upon the receipt of written complaint, ICC shall endeavour to settle the matter, provided the Complainant has requested for a conciliation. If not, the ICC shall issue a copy of the Complaint to the accused/Respondent i.e., the person against whom a complaint is filed.

  5. The Respondent shall then file his written reply within 10 working days from date of receipt of complaint copy. Once ICC receives reply from Respondent, the inquiry shall commence. Such inquiry shall be conducted by a minimum of 3 members of the ICC, including the Presiding Officer and it shall be conducted as per the service rules of the Respondent. Principles of natural justice shall be followed during such inquiry and legal practitioners shall not be allowed to represent either party. Inquiry must be completed within a period of 90 working days. Parties are required to participate in the investigation and furnish evidence in respect of the statements made by them. Noodlers understand that the ICC is not obligated to investigate a complaint and any assistance provided in that regard will be only in the interesting of ascertaining facts. All the proceedings of investigation shall be recorded in writing and one copy each shall be given to the Parties at the end of each sitting of inquiry.

  6. Interim measures: During the pendency of the inquiry, on a written request made by the Complainant or the aggrieved person, the Committee may recommend: (a) a transfer of the Complainant or the alleged accused to any other department or office of Company, (b) restraining the Respondent from reporting on the work performance of the Complainant or writing her confidential report and assign the same to another office, (c) grant of leave to the Complainant up to a period of 3 (three) months or until the conclusion of inquiry; or (d) grant of such other relief, as may be prescribed under applicable law. However, any leave granted herein shall be in addition to the leave that such individual would be otherwise entitled to.

  7. The Committee shall have the right to terminate the inquiry or pass an exparte decision on the complaint, in the event the Complainant or the respondents fail, without reasonable cause, to present themselves for 3 (three consecutive hearings. However, an ex-parte order will not be passed by the committee without giving written notice of 15 (fifteen) days to the relevant party.

  8. Upon completion of the enquiry the committee shall furnish one copy each to the parties to complaint and submit one copy of the findings report to the ‘employer’ i.e., the Managing Director. If there is a difference of opinion among members of the committee in respect of any matter, the opinion of the majority shall prevail. Provided that where there is no such majority, the opinion of the presiding officer shall prevail. Such report shall be shared within 10 working days from date of conclusion of inquiry and the employer shall initiate action within 60 working days from date of receipt of report.

  9. If either the Complainant or the Respondent is unhappy with the decision of the Committee, they may appeal against the same within 90 working days to the ‘Appellate Authority’ prescribed under the Act and Rules.

  10. Reasonable efforts will be made to keep the investigation of the complaint confidential to the extent possible except as necessary to investigate the incident. As such, the Noodler reporting the concern, and all those involved in providing information for the investigation are instructed to not discuss the investigation with other Noodlers. Such discussions may hamper the investigation, cause further disruptions in the workplace and inadvertently tamper with evidence/testimony important to the investigation. Violation of confidentiality shall result in disciplinary action.

  11. Should the Company determine through the investigation that an individual is guilty of sexual harassment, action appropriate to the offense will be taken against the Respondent. Actions/ penalties potentially include training/counselling, monitoring, job change, monetary penalty, disciplinary action, up to and including discharge or equivalent penalty for non-Noodlers.

  12. False complaint: If through the investigation, the Company finds that a complaint is not bona fide, or was made in bad faith/malicious intent, or that a Noodler or witnesses have provided false information about the complaint, disciplinary action shall be taken against those individuals accordingly.

The Company expressly prohibits any form of retaliatory action against any Noodler for filing a bona fide complaint under this policy or for assisting in or providing information related to a complaint investigation. Supervisors in receipt of any complaint of possible harassment/discrimination/retaliation are required to inform the same to ICC team immediately, so that the ICC team/ committee can initiate an investigation of the incident as described in the above procedure. Failure to do so may result in disciplinary action or personal liability towards such supervision.

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