POSH ACT – 2013

Policy on Prevention of Sexual Harassment at Workplace

Commitment

Our Company is committed to providing work environment that ensures every employee is treated with dignity and respect and afforded equitable treatment. The Company is also committed to promoting a work environment that is conducive to the professional growth of its employees and encourages equality of opportunity. The Company will not tolerate any form of sexual harassment and is committed to take all necessary steps according to the POSH Policy to ensure that its employees are not subjected to any form of harassment.

Scope

This policy applies to all employees (full-time, part-time, trainees and those on contractual assignments) of the Company including all subsidiaries and affiliated companies at their workplace or at client sites. The Company will not tolerate sexual harassment, if engaged in by clients or by suppliers or any other business associates. The workplace includes:

• All offices or other premises where the Company’s business is conducted.
• All company-related activities performed at any other site away from the Company’s premises.
• Any social, business or other functions where the conduct or comments may have an adverse impact on the workplace or workplace relations.

Definition of Sexual Harassment

Sexual harassment among the other elements of the POSH Act, may be one or a series of incidents involving unsolicited and unwelcome sexual advances, requests for sexual favours, or any other verbal or physical conduct of sexual nature. Sexual Harassment at the workplace includes:

“Sexual Harassment” includes any one or more of the following unwelcome acts or behavior, whether directly or by implication:

• Physical contact or advances;
• Demands or requests for sexual favours;
• Making sexually coloured remarks or engaging in pranks, teasing, and jokes of a sexual nature;
• Showing pornography;
• Any other unwelcome physical, verbal or non-verbal conduct of a sexual nature;
• Presence or occurrence of circumstances of implied or explicit promise of preferential treatment in employment;
• Threat of detrimental treatment in employment;
• Threat about present or future employment;
• Interference with work or creating an intimidating or offensive or hostile work environment;
• Humiliating treatment likely to affect an employee’s health or safety.

Sexual harassment may occur not only in a situation where a person uses sexually tinted behavior or actions to control, influence, or affect the career, salary, or job of another person but also between co-workers or between a Bonanza Portfolio Limited employee and someone the employee deals with during his or her course of work and who may or may not be an employee of Bonanza Portfolio Limited.

Responsibilities regarding Sexual Harassment

All employees of the Company have a personal responsibility to ensure that their behaviour is not contrary to this policy. All employees are encouraged to reinforce the maintenance of a work environment free from sexual harassment that’s falls under criteria for POSH.

Complaint Mechanism

An appropriate complaint mechanism in the form of “Complaints Committee” has been created in the Company for time-bound redressal of the complaint made by the victim.

Complaints Committee

If the aggrieved employee chooses not to use conciliation as a redressal mechanism, or if the parties cannot reach a settlement through conciliation, or if the terms of settlement arrived at through conciliation are not adhered to, the Internal Complaints Committee may initiate a formal inquiry into the complaint within 1 week of:

• Receiving the POSH complaint and if the aggrieved employee chooses not to use conciliation as a redressal mechanism,
• The expiry of the conciliation period wherein no settlement is arrived at, or
• Notice that the terms of settlement are not being adhered to.

The formal inquiry by the Internal Complaints Committee shall not exceed a period of 30 days from its commencement. The inquiry conducted by the Internal Complaints committee must be in accordance must be in accordance with the principles of natural justice.

On completion of the inquiry, which may include interviewing the aggrieved employee and/or the respondent, studying of available evidence, listening to statements of witnesses, etc., the Internal Complaints Committee shall create a report that contains the findings of the inquiry, and forward it to the employer for further action. A copy of such report must also be provided to the aggrieved employee and the respondent.

Harassment

The Company is committed to providing a supportive environment to resolve concerns of sexual harassment as under: Informal Resolution Options When an incident of sexual harassment occurs, the victim of such conduct can communicate their disapproval and objections immediately to the harasser and request the harasser to behave decently. If the harassment does not stop or if victim is not comfortable with addressing the harasser directly, the victim can bring their concern to the attention of the Complaints Committee for redressal of their grievances. The Complaints Committee will thereafter provide advice or extend support as requested and will undertake prompt investigation to resolve the matter.

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 the 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 the 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 employees, a workplace free from harassment/ discrimination and where every employee is treated with dignity and respect.