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Anti-Sexual Harassment Policy

1. Introduction
Indegene believes that all its employees have the right to be treated with respect and dignity. The organisation is committed towards creating a healthy working environment that enables its employees to work without fear, prejudice, gender bias or sexual harassment.
In accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (hereinafter referred to as the ‘Act’) and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013 (hereinafter referred to as the ‘Rules’), the organisation has framed the following policy (the ‘Policy’) for prevention of sexual harassment at the workplace.
2. Purpose and Scope of the Policy
Indegene is committed towards providing a work environment that ensures every employee is treated with dignity and respect and afforded equitable treatment. The organisation is also committed towards promoting a work environment that is conducive to the professional growth of its employees and encourages equality of opportunity.
The organisation will not tolerate any form of sexual harassment and is committed to take all necessary steps to ensure that its employees are not subjected to any form of harassment. This Policy seeks to provide awareness to all employees of Indegene on what actions constitute sexual harassment, the redressal mechanism in place and the penal consequences (both interim and final) imposed on perpetrators of sexual harassment.
3. Policy Descriptiton
This Policy applies to all categories of employees of the organisation, including permanent employees, permanent management, workmen, temporary employees, trainees, consultants, advisers, ad hoc employees, daily wage earners, probationers, apprentices, employees on contract, etc. at their respective workplaces or at the offices of partner organisations during official visits. The Policy is applicable to all categories of employees as stated above, irrespective of whether those employees have been engaged directly or through an agency or a contractor, and whether those employees are working for remuneration or on a voluntary basis.
The Policy shall also be applicable to all third parties such as visitors, clients, customers, contractors, service providers, and any other person authorised to be present within the premises/workplace of Indegene.
The organisation will not tolerate sexual harassment, if engaged in by partners, or by suppliers or any other associates of the organisation. It shall extend to cover sexual harassment of women by men, of men by women or between the same sexes. Harassment is unlawful irrespective of who is involved in the behaviour.
4. Definition of Terms
‘Complainant’ means, in relation to a workplace (as hereinafter defined), an individual, of any age whether employed or not, who alleges to have been subjected to any act of sexual harassment by the Respondent (as hereinafter defined);
‘Employees’ means all employees of Indegene as set out in Clause 3.1 of this Policy and includes all categories of employees of the organisation including both part-time or full time, and not limited to:
Permanent employees
Temporary employees
Trainees and interns
Contract resources
‘Employer’ means and includes:
CEO of Indegene
Any person(s) or board or committee responsible for the formulation and administration of policies that enables management, supervision and control of the workplace.
‘Internal Committee (IC)’ means a committee constituted by the Employer for the purpose of dealing with all matters in relation to sexual harassment;
‘Member/s’ means a Member/s of the Internal Committee;
‘District Officer’ means an officer notified under Section 5 of the Act
‘Local Committee’ or ‘LC’ means a committee notified by the State Government for the purpose of dealing with matters in relation to sexual harassment in each and every district;
‘Respondent’ means a person (employee) against whom the complainant has made a complaint of sexual harassment;
‘District Officer’ means an officer notified under Section 5 of the SHWW (PPR) Act 2013.
‘Sexual harassment’ includes any one or more of the following unwelcome acts or behaviour (whether directly or by implication):
Making a physical contact and advances
Making a demand or request for sexual favours
Making sexually coloured remarks
Showing pornography
Involving in any other unwelcome physical, verbal or non-verbal conduct of sexual nature.
The following circumstances, among other circumstances, if it occurs or is present in relation to or connected with any act or behaviour of sexual harassment, may amount to sexual harassment at the workplace:
Implied or explicit promise of preferential treatment in the complainant’s employment
Implied or explicit threat of detrimental treatment in the complainant’s employment
Implied or explicit threat about the complainant’s present or future employment status
Interference with the complainant’s work or creating an intimidating or offensive or hostile work environment for the complainant
Humiliating treatment likely to affect the complainant’s health or safety
‘Workplace’ means and includes the offices of Indegene as well as the premises of other third parties, vendors and associates of Indegene where the employees of Indegene are required to perform work or where the employees of Indegene visit during the course of employment, and also includes transportation provided by Indegene for undertaking any journey, in connection with the business of Indegene.
5. Constituents of Sexual Harassment
Conduct must be unwelcomed, unwanted, uninvited, unreasonable, and/or offensive to the complainant which adversely affects the dignity of the complainant.
Physical contact is not an essential factor for sexual harassment.
A person’s rejection of or submission to such conduct is used explicitly or implicitly as a basis for a decision which affects that person’s job.
Conduct that creates an intimidating, hostile or humiliating working environment for the complainant.
Act of sexual harassment must be related to employment or work. Hence, acts committed outside the office, for example in the cafeteria, on business travel in a flight or hotel, place of visit for official purpose such as client premises, offices, official events, etc. are covered. Additionally, acts that are committed during Work from Home arrangements that are authorized and/ or mandated by the organization would fall within the ambit of sexual harassment at the workplace. “Work from Home” here refers to a situation wherein Employees are working from a remote location which is not the organization’s physical premises, client/ vendor premises, or any other location within the ambit of Clause 4(j) of this policy. Actions which take place in personal capacity will not be considered workplace concerns unless there is connection with the workplace by way of creation of a hostile work environment for the aggrieved person.
The respondent can be whomsoever, provided Indegene has sufficient control over the said person and, without limitation, can be the complainant’s boss, supervisor, sub-ordinate, trainer, colleague, mentor, co-worker, vendor, contractor or agent of the employer.
6. Exclusion
It is to be noted that this Policy does not apply when the complainant is performing work outside of workplace, of their own accord and for personal reasons.
7. Third Party Harassment
Third party harassment means sexual harassment perpetrated by visitors, patrons, vendors, independent contractors, auditors, consultants, and others with whom the employees have directly or indirectly come in contact because of Indegene’s business relationship with them.
Where the sexual harassment at the workplace occurs as a result of an act or omission by any third party, Indegene shall take all steps necessary and reasonable to assist the affected employee in terms of support and preventive action.
8. Prevention of Sexual Harassment
Indegene will not tolerate any form of sexual harassment and will strive through education and deterrence to create an environment that is free from sexual harassment.
All employees are expected to:
Treat others with respect and dignity.
Refrain from actions that may offend, embarrass or humiliate others (whether deliberate or unintentional).
Let others know they don’t approve of disrespectful or harassing behaviour.
Apologise if someone tells them they are offended by their words or actions
Familiarise themselves with this Policy.
9. Zero Tolerance to Retaliation
If an employee feels that he/she is experiencing any kind of retaliation, victimisation or discrimination in the nature of intimidation, pressure to withdraw the complaint or threats for reporting, testifying or otherwise participating in the proceedings, he/she should immediately report the matter by sending an email to the dedicated email id POSH@Indegene.com. All members of the Internal Committee (IC) are mapped to or included in this email id. Indegene prohibits retaliation against anyone for raising a complaint or helping in addressing the complaint. Any retaliation or reprisals are subject to immediate corrective action, up to and including termination of services. Alleged retaliation or reprisals are subject to the same complaint procedures and disciplinary action as complaints of sexual harassment.
Inquiry process with templates: It is to be noted that the templates are for guidance only. Internal Committee may make changes as required depending on the facts and circumstances of the case.
10. Conflict of Interest Policy
Indegene discourages romantic or sexual relationships between a member of management or other supervisory employee and his or her staff (an employee who reports directly or indirectly to that person), because such relationships tend to create compromising conflicts of interest at work.
It is therefore in the best interest of all concerned that if there is such a relationship, the involved parties notify management so the reporting chain can be changed to ensure no direct or indirect reporting relationship.
11. Internal Committee
The IC shall consist of the following members namely: (a) a Presiding Officer who shall be a woman employee at a senior level; (b) not less than two members from amongst employees who have had experience in social work or have legal knowledge; (c) one member from amongst non-governmental organisations or associations committed to the cause of women or a person familiar with the issues relating to sexual harassment. One half of the total members so nominated shall be women. The names and contact details of the members of the IC shall be communicated by the employers to the employees from time to time as applicable.
The Presiding Officer and every member of the IC shall hold office for a period not exceeding (3) three years from the date of nomination.
The procedure as regards the IC shall be as contemplated under the provisions of the Act.
12. Complaint of Sexual Harassment
In the event the complainant is unable to make a complaint on account of the Complainant’s physical or mental incapacity or death or any other reason which prevents the complainant from making a complaint, then the Complainant’s legal heir or any other person as mentioned below may make the complaint on the Complainant’s behalf under the Policy:
In the event the complainant is unable to make the complaint on account of complainant’s physical incapacity, the complaint may be filed by:
Complainant’s relative or friend;
Complainant’s co-worker;
an officer of the National Commission for Women or State Women’s Commission (in case the Complainant is a woman); or
Any person who has knowledge of the incident, with the written consent of the complainant.
In the event the complainant is unable to make the complaint on account of complainant’s mental incapacity, the complaint may be filed by:
the complainant’s relative or friend;
a special educator;
a qualified psychiatrist or psychologist;
the guardian or authority under whose care the complainant is receiving treatment or care; or
Any person who has knowledge of the incident jointly with the complainant’s relative or friend, or a special educator or qualified psychiatrist or psychologist, or guardian or authority under whose care the Complainant is receiving treatment or care.
In the event the complainant is unable to make the complaint for any other reason, the complaint may be filed by any person who has knowledge of the incident, with the complainant’s written consent.
In the event of the death of the complainant, the complaint may be filed by any person who has knowledge of the incident, with the written consent of the complainant’s legal heir.
A complainant may make the written complaint to the IC. No particular form is required; however, the complaint must be in writing and must be signed by the complainant.
Any employee may make a complaint of sexual harassment at workplace to the IC of the particular location within a period of three months from the date of the incident.
The IC is empowered to extend the time limit beyond three months from the date of incident, but not exceeding three months thereafter, for reasons to be recorded in writing if the IC is satisfied that the circumstances were such which prevented the person from filing the complaint within the said period.
The Presiding Officer or any Member of IC may also render reasonable assistance to the Employee for making any complaint in writing, if he/she cannot make the complaint in writing themselves.
Legal heirs or such other persons may also make the complaint if the complainant is unable to make the complaint on account of his/her trauma, physical or mental incapacity or death or otherwise.
A withdrawal of the complaint made or filed at any stage of the proceedings shall not preclude the IC from proceeding with the investigation of the complaint.
If so, requested in writing, by the complainant, pending completion of the inquiry, the IC may recommend the employer to:
Transfer the complainant or the respondent to any other workplace; or
Grant leave up to 3 months to the complainant; or
Grant such other relief to the complainant as maybe prescribed in the Rules, including restraining the respondent from reporting on the work performance of the complainant or writing any confidential report and assign the same to another officer.
The employer shall implement such recommendations and send a report of such implementation to the IC.
Note: In the event that the complainant is granted leave in accordance with this Policy, such leaves shall be in addition to the leave the Complainant is otherwise entitled to.
13. Conciliation
The complainant can request for conciliation before commencement of an inquiry by the IC.
No monetary settlement shall be made as a basis of conciliation.
The IC shall then record the settlement so arrived and forward the same to the employer to take action as specified in the recommendation.
The IC shall provide the copies of the settlement to the complainant and the respondent.
Where a settlement is arrived under conciliation, no further inquiry shall be conducted by the IC.
While any conciliation proceeding shall ordinarily be conducted in face-to-face meetings, Clause 15.9 more fully describes other modes of conducting the same
Note: In cases where the complainant feels that it is a minor instance which could be redressed through conciliation settlement, only in such cases, conciliation can be arrived at.
14. Inquiry of Complaint
The IC shall follow the prescribed procedures. The IC shall, where the respondent is an employee, proceed to make inquiry into the complaint in accordance with the provisions of the service rules applicable to the respondent, and where no such rules exist, in such manner as maybe prescribed under the Rules.
In case of breach of the terms of conciliation settlement, an inquiry shall also be held to look into such breach.
IC shall give both the parties an equal opportunity of being heard.
The inquiry shall be completed within 90 days from the date of complaint.
IC shall forward the copy of findings to both the parties to make representation against findings of the IC.
15. Inquiry Procedure
The complainant shall submit/send by e-mail copy of the complaint, supporting documents and list of witnesses to the IC.
One copy of the complaint should be sent to respondent after receipt of the complaint within 7 working days by the IC.
The respondent shall file his/her reply within 10 working days from the date of receipt of the complaint with his/her list of documents and the list of witnesses.
IC should follow the principles of natural justice during the course of proceedings.
IC may, at its discretion, conduct the ex-parte inquiry if the complainant or the respondent fails without sufficient cause to present themselves for 3 consecutive hearings convened by IC. However, such ex-parte order may not be passed without giving a notice in writing at least 15 days in advance to the party remaining absent from the proceedings.
No legal practitioner is allowed to be brought by the parties to represent them in their case at any stage of the proceedings before the IC.
Minimum of 3 members including Presiding Officer and the external member shall be present while conducting the inquiry.
For the purpose of initiating an inquiry wherein the complainant is an aggrieved woman, the IC shall have the same powers as are vested in a civil court under the Code of Civil Procedure, 1908 when trying a suit in respect of the following matters, namely:
Summoning and enforcing the attendance of any person and examining him on oath;
Requiring the discovery and production of documents; and
Any other matter as may be prescribed
While the inquiry/ conciliation proceedings shall ordinarily be conducted face-to-face with the parties and witnesses physically appearing for meetings at the office premises or any other location specified by the IC, in certain circumstances, the IC may allow the parties or witnesses to appear before it through videoconference or telephonic means. In such situations, the following guidelines shall also be observed:
Videoconference or telephonic proceedings shall be conducted only with the consent of the parties and witnesses involved.
The parties or witnesses who are required to depose before the IC shall be given adequate notice of 24 hours to ensure that they have enough time to set up the infrastructure required for taking a video-conference call.
The IC members/ parties/ witnesses to any inquiry or conciliation will be bound by the same standards of confidentiality as in the case of face-to-face proceedings. Audio or video recording of proceedings shall not be permitted. The IC member/ party/ witness appearing through virtual means must ensure that they are alone in the room when taking the call and that no part of information relating to the proceedings is made known to any unauthorized individual.
Parties/ witnesses will be sent a copy of the minutes of meetings or other relevant documentation (such as inquiry/ findings reports, evidence etc.) via email.
Any and all communication (including but not limited to consent, confirmations, questions, comments, responses, statements) shall be made through email and/ or digital signatures.
In the event that videoconference or telephonic proceedings are not feasible, the IC may postpone the same until physical meetings can be conducted.
16. Inquiry Procedure
The IC shall provide report of the findings to the employer and both the parties within a period of 10 days from the date of completion of inquiry.
The employer shall act upon the recommendation within 60 days of the receipt of the findings report.
If the IC arrives at the conclusion that the allegation against the respondent has not been proved, it shall recommend to the employer that no action is required to be taken.
If the IC arrives at the conclusion that the allegation against the respondent has been proved, it shall recommend to the employer to:
Take action for sexual harassment as a misconduct in accordance with the provisions of the service rules applicable or where no such service rules have been made, in such manner as prescribed under the Rules
Deduct, notwithstanding anything in the service rules applicable to the respondent, from the salary or wages of the respondent such sum as it may consider appropriate to be paid to the complainant or to her legal heirs, as it may determine, in accordance with the provisions of Section 15 of the Act. In the event the employer is unable to deduct the same or in the event of non-payment of the above-mentioned sum by the respondent, the same shall be recovered in a manner as prescribed under Section 13 of the Act.
17. Penalties
Consequences of violation of the Policy: Any person found guilty of violating this Policy as substantiated by data and facts, will be subject to any of the below mentioned disciplinary action, leading up to and including termination of services with/or without compensation based on severity of case.
Written apology
Reprimand or censure
With-holding of promotion
With-holding of pay rise or increments
Terminating of service
Undergoing a counselling session
Carrying out community service
Monetary compensation
Irrespective of and without prejudice to complaints initiated before the IC, the complainant may, at his/her sole discretion, also choose to lodge a complaint for the same offence with the police. The IC shall provide reasonable assistance to the police in its investigation. IC may take note of the findings by the police and/or any other competent authority, in arriving in its recommendations and conclusion. The respondent shall be subject to any findings or order of any competent authority, including but not limited to, a Court of Law.
Punishment for false or malicious complaint and false evidence: If the complaint is found to be false and malicious, the complainant shall be liable for appropriate disciplinary action. However, this shall not include complaints in respect of which the investigation has remained inconclusive due to circumstances which have rendered the offence difficult to prove and/or such complaints which have been made in good faith. The malicious intent on the part of the complainant shall be established after an inquiry in accordance with the procedure prescribed before any action is recommended.
Penalty for publication or making known contents of complaint and inquiry proceedings: Where any person entrusted with the duty to handle or deal with the complaint, inquiry or any recommendations or action to be taken under the provisions of the Act violates confidentiality, he/she shall be liable for penalty as maybe prescribed in the Rules. where any employee who is part of the proceedings of the complaint as a witness, complainant and/or respondent violates the confidentiality provisions of this Policy, he/she shall be subject to appropriate disciplinary action.
18. Appeal
The complainant and the respondent shall have the right to appeal to the Tribunal/Court of Appropriate Jurisdiction within 90 days of the decision of the IC if they are not satisfied with the decision of the IC.
19. Local Committee
If the Employer is unable to recover the amount of compensation from the respondent, employer shall forward the Inquiry Report to the District Officer of the Local Committee.
If the complaint is against the employer himself, complaints can be filed before the District Officer of the Local Committee.
20. Filing of Police Complaints
If the complainant so desires, it is the duty of the employer to assist the complainant in filing the complaint with the Police.
If it is a grave offence, then the employer is duty-bound to report the matter to the Police.
21. Savings
The proceedings under this Policy shall be conducted in parallel with the other remedies of law, if such a case arises.
The provisions of this Policy shall not restrict the power of the employer or the complainant to proceed against the respondent for any other misconduct or to pursue the criminal or civil remedies.
22. Examples of Instances Construed as Sexual Harassment
Sexual harassment is classified as below, which includes (but is not limited to) the following:
Surreptitiously looking or prolonged staring at a person, giving rise to gross discomfort to the person
Telling sexist and/or smutty jokes or sending these through text, electronic mail or other similar means, causing embarrassment or offense, and the same being carried out after the offender has been advised that they are offensive or embarrassing or, even without such advice, when they are by their nature clearly embarrassing, offensive or vulgar;
Malicious leering or ogling
Displaying sexually offensive pictures, materials or graffiti
Making unwelcoming inquiries or comments about a person’s sex life
unwelcome sexual flirtation, advances and propositions
Making offensive hand or body gestures
Persistent unwanted attention with sexual overtones
unwelcome phone calls with sexual overtones causing discomfort, embarrassment, offense or insult to the receiver or any such verbal or virtual communication with sexual overtones causing discomfort, embarrassment, offense or insult to the receiver
Unsavoury remarks about a person’s physical characteristics, dressing, attitude, etc.
Sexual assault
Malicious and/or unwanted touching or brushing against a victim’s body
Requesting for sexual favours in exchange for employment, promotion, local or foreign travels, favourable working conditions or assignments, a passing grade, the granting of honours or scholarship, or the grant of benefits or payment of a stipend or allowance
Derogatory or degrading remarks or innuendoes directed toward the members of one sex, or one’s sexual orientation or used to describe a person
Verbal abuse with sexual overtones
Other analogous cases
23. Names and Contact Details of the Members of the IC
The names and contact details of the members of the IC shall be as communicated by internal communication and posters displayed to the employees from time to time.
Displayed as per the decision of the Supreme Court in Aureliano Fernandes v. State of Goa dated 12th May 2023, paragraph 77(ii):
Information regarding the constitution and composition of the Internal Committee (IC) along with details of the email IDs and contact numbers of IC members:
In accordance with section 4(2) read with section 19(b) of the Sexual Harassment of women at Workplace (Prevention, Prohibition and Redressal) Act and the Rules, 2013, the Internal Committee consisting of the following members is constituted.
Ms. Anjali Joisa (External Member) - anjali@sashaindia.com
Ms. Aparajita Konamaneni (Member) - aparajita.k@indegene.com
Ms. Chandana H G (Member) - chandana.hosurkoppa@indegene.com
Ms. Chithra Prasad (Member) - chithra.prasad@indegene.com
Mr. Deepak Arora (Member) - deepak.arora@indegene.com
Ms. Geethashree H S (Member) - geethashree.shambu@indegene.com
Ms. Jhanvi Dhawan (Member) - jhanvi.dhawan@indegene.com
Ms. Kanchan Kumari (Member) - kanchan.kumari@indegene.com
Ms. Kanti Joshi (External Member) - kanti@sashaindia.com
Mr. Karthik Kannappan Saravanan (Member) - karthik.kannappan@indegene.com
Ms. Ponangi Arathi (Member) - arathi.ponangi@indegene.com
Ms. Leena Rajan (Member) - leena.rajan@indegene.com
Ms. Manjula S (Member) - manjula.sudhakar@indegene.com
Ms. Priyanka Shetty (Alternate Presiding Officer) - priyanka.shetty@indegene.com
Ms. Seema Srinivasan Chakravarthi (Member) - seema.chakravarthi@indegene.com
Ms. Soundarya Mahalingam (Presiding Officer) - soundarya.mahalingam@indegene.com
The formation of the committee shall be effective from 26th May 2023 and shall be in force for a period of 3 years. Any vacancies arising during the said period will be filled up in accordance with the provisions of the Act and Rules read with the policy of the company.
Procedure prescribed for submitting an online complaint: For filing a complaint of sexual harassment, complaint can be sent to email- posh <posh@indegene.com>. Redressal proceedings will be initiated in compliance with Sexual Harassment of women at Workplace (Prevention, Prohibition and Redressal) Act and the Rules, 2013.
Relevant rules, regulations and internal policies: Indegene Limited has formulated a policy on prevention and redressal of sexual harassment in compliance with the Sexual Harassment of women at Workplace (Prevention, Prohibition and Redressal) Act and the Rules, 2013. You may request for a copy of the same by sending an email to - posh <posh@indegene.com>.
The information furnished is updated as on 10th July 2023.
24. Annual Report of the IC
The IC shall in each calendar year prepare an annual report in the prescribed form and submit the same to the employer and the District Officer. The report shall encompass the following:
Number of complaints received that year
Number of complaints disposed of during that year
Number of workshops or awareness programmes conducted
Number of cases pending for more than 90 days
Nature of action taken by the employer
25. Timelines Under the Act
1ComplaintComplaint to be lodged by employee before IC

Within the period of 3 months from the date of the incident, or

In case of series of incidents, within the period of 3 months from the date of last incident

2Initiation of Inquiry ProceedingsBy the IC, by sending the copy of complaint to the respondentWithin the period of 7 working days of receipt of the complaint
3Reply by the respondent along with his list of documents, names and addresses of witnessesTo the ICWithin 10 working days from the day of receipt of the copy of complaint forwarded by the IC
4Completion of Inquiry proceedingsBy ICWithin 3 months from the date of receipt of complaint
5Submission of Inquiry Report and Findings along with Recommendations by ICTo the EmployerWithin 10 days of completion of Inquiry Proceedings by IC
6Implementation of recommendations made in the inquiry report of the ICBy the employerWithin 60 days of the receipt of the recommendations made in the inquiry report by the IC
7Appeal under clause 15.1 of the PolicyBy the aggrieved personWithin a period of 90 days of Recommendations by IC
26. Senior Management Approval
As per the IC committee, it has been reviewed and approved by Presiding officer – Bina Patil and Core Advisory member- Anand Kiran.

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