Policy on Sexual Harassment of Women at Workplace
(Prevention, Prohibition and Redressal)

Last updated:

May 27, 2026

Purpose
1. It is the policy of the Company to provide an environment free from harassment for any reason, whether because of age, race, color, religion, gender, creed, national origin, disability, or any other factor, especially sex. Sexual harassment violates an individual’s fundamental rights and personal dignity, is unlawful, and will not be tolerated by the company.
2. The company considers sexual harassment in all its forms to be a serious offense and has zero- tolerance towards sexual harassment.
3. Company will take action against an employee found guilty of violating this Policy, after following the due process, based on the provisions of the Act and principles of natural justice. Therefore, it is the responsibility of all those connected therewith to comply with this policy.
4. Company has drafted its Sexual Harassment Policy described below based on the Sexual Harassment of Women at the Workplace (Prevention, Prohibition and Redressal) Act, 2013 and Rules framed there under.
Objective of the Policy
1. To provide a secure working environment for women employees that is free from fear, reprisal, coercion, discrimination and sexual harassment.
2. To prevent discrimination and sexual harassment by making it clear that such behaviour and conduct is prohibited.
3. To ensure that all employees are acquainted with this Policy and are provided the necessary information and training to prevent and to handle complaints of sexual harassment.
4. To support immediate reporting of any act of sexual harassment and to provide a just, sensitive and timely handling of sexual harassment complaints; to take disciplinary action against those who have violated this Policy.
Who is covered under the Policy framework?
1. The Policy framework is applicable to all complaints of sexual harassment made by a woman employee and against all Organisation employees irrespective of whether the harassment has taken place during the period of employment and/or within or beyond the confines of the offices or Company.
2. It applies to all individuals who are employed in a permanent, contractual, temporary, volunteer, or internship capacity at any Company office location.
3. This policy framework is applicable to all the Company offices, and each is mandated to apply a similar approach in dealing with this issue.
Definition
1. Sexual harassment is unwanted sexual attention of a persistent or offensive nature made by a person who knows, or reasonably should know, that such attention is unwanted. Sexual harassment includes sexually oriented conduct that interferes with an employee’s job performance and creates an intimidating, hostile, or offensive working environment.
2. The Act defines Sexual Harassment as any one or more of the below mentioned unwelcome sexual acts or behavior, whether directly or indirectly, as:
  1. Physical contact and advances: assault, staring or targeting unreasonable attention at an individual in day-to-day dealings.
  2. A demand or request for sexual favors: whether by words or actions, is made a condition for an individual’s employment, career progress, promotion etc. thereby creating a hostile environment.
  3. Making sexually colored remarks: derogatory statements, slurs, jokes of an inappropriate nature.
  4. Showing pornography: sexual visuals, sexual audios, or obscene material.
  5. Any other unwelcome physical, verbal/non-verbal conduct of a sexual nature.
  6. Transmitting any message, by mail, telephone, e-mail etc. which is obscene, lewd, suggestive, or blatantly sexual in nature.
3. Also, if the following circumstances, among other circumstances, occurs or is present in relation to or connected with any act or behaviour of sexual harassment, then that act or behaviour would also amount to sexual harassment:
  1. Implied or explicit promise of preferential treatment in employment.
  2. Implied or explicit threat of detrimental treatment in employment.
  3. Implied or explicit threat about her present or future employment status.
  4. Interference with work or creating an intimidating/hostile/offensive work environment.
  5. Humiliating treatment likely to affect her health and safety.
4. This is an indicative and not an exhaustive list of possible forms of sexual harassment.
5. Consensual sexual or romantic relationships between employees are deemed unwise and are strongly discouraged especially if one employee has supervisory authority over the other employee. It does not refer to office relationships that are freely entered into without intimidation or coercion.
6. In the now prevalent ‘work from home’ situations the definition of ‘workplace’ shall reflect a wider interpretation; likewise, the scope of 'acts of sexual harassment' too shall reflect a broader interpretation.
7. The management enjoins employees to treat ‘work from home’ based virtual/video meetings, discussions and conversations between employees as ‘work and workplace related interactions’ falling under the preview of the POSH Act.
8. Consequently, in keeping with the Company’s intent and spirit of ‘a safe working space for all employees’, every employee participating in virtual/video meetings shall:
  1. Take suitable care and precautions to ensure that he/she is suitably dressed for all virtual/video meetings.
  2. Avoid the display of any provocative images/backdrops on their home screen.
  3. Avoid any acts defined as acts of sexual harassment under the Company’s Policy.
  4. Ensure that any third parties visible to other employees participating in a virtual /video meeting, via an employee’s home screen, do not perform any acts that may be interpreted as acts of sexual harassment.
  5. Be responsible and accountable for images/backdrops and the behaviour of third parties visible to other employees via an employee’s home screen and be liable as a ‘Respondent’ in case of a complaint of sexual harassment under the Policy.
Responsibilities
1. If any woman employee believes that they have been subject to sexual harassment or any unwanted sexual attention by anyone (e.g., a coworker, company patron or other person), they can report the incident immediately with the Internal Complaints Committee by email at
  harassment@ac-wcrgroup.com
2. Make their unease and/or disapproval directly and immediately known to the alleged harasser;
3. Report the incident immediately to the HR Manager against that individual. The Human Resource Department will assist the complainant to file a complaint with the Internal Complaints Committee of the Company.

The Grievance Resolution Mechanism

Company has established the following process to ensure that any incidence of sexual harassment is dealt with appropriately, sensitively and expeditiously.

The Internal Complaints Committee (ICC): Shall presently comprise of –

Sr. No.	Name Member of the	Designation	Contact Number	Email address
1	Ms. Bhavika Shah	Presiding officer	9920609811	bhavika.s@ac-wcrgroup.com
2	Mr.Vaibhav Deshpande	Member	9920997624	vaibhav.d@ac-wcrgroup.com
3	Gurpreet Kaur Jaspeet Singh Putiani	Member	9820247473	gurpreet.k@ac-wcrgroup.com
4	Mr. Anand Satyadev Sharma	Member	9821355771	anand.s@ac-wcrgroup.com
5	Mr. Dhaval Kelkar	Member	9819370917	dhaval.k@ac-wcrgroup.com
6	Ms. Priti Upadhyay	Member	9967442996	priti.upadhyay@whitecrowdigital.in
7	Ms. Persis Sidhva	External member	9821173549	sidhva.persis@gmail.com

Tenure of the ICC Members :
1. The ICC shall be headed by a woman and not less than half of its members shall be women.
2. The ICC member shall hold office for period not exceeding 3 years from the date of nomination.
3. In the event of any proven complaint against any member of the ICC, the concerned member shall be removed from the ICC and the vacancy shall be filled by a fresh nomination.
Role of the ICC:
1. Preventive:
  1. To create and ensure a safe environment that is free of sexual harassment
  2. To maintain an atmosphere of equality and gender justice
  3. To publicize the policy with the names and phone numbers of members of the ICC
2. Remedial:
  1. To take notice of complaints of sexual harassment, conduct enquiries, provide assistance
  2. To redress the complaints of sexual harassment, recommend penalties and take action against the respondent, if necessary
  3. To recommend to the concerned authorities follow-up action and to monitor the same
3. Preparation of the Annual Report:
  Shall contain the following information -
  1. Number of complaints of sexual harassment received during the year;
  2. Number of complaints disposed of during the year;
  3. Number of cases pending for more than 90 days;
  4. Number of workshops or awareness programs against sexual harassment carried out;
  5. Nature of action taken by the employer.
Complaints Handling Process:
1. Any aggrieved woman may make, in writing, a complaint of sexual harassment at her workplace, to the ICC, within a period of 3 months from the date of the incident and in case of a series of incidents, within a period of 3 months from the date of last incident. The ICC may for reasons to be recorded in writing, extend the time limit for a further period of 3 months, if in the opinion of the ICC, circumstances existed which prevented the woman from filing her complaint.
2. Where an aggrieved woman is unable to make a complaint in writing, the Presiding Officer or any Member of the ICC shall render all reasonable assistance to the woman to make her complaint in writing.
3. Where the aggrieved woman is unable to make a complaint on account of her physical incapacity, a complaint may be filed by a relative or friend, or a co-worker, or an officer of the National Commission for Women or the State Women’s Commission; or any person who has knowledge of the incident, with the written consent of the aggrieved person.
4. Where the aggrieved person is unable to make a complaint on account of her mental incapacity, a complaint may be filed by a relative or friend, or a special educator, or a qualified psychiatrist or psychologist, or the guardian, or the authority under whose care she is receiving treatment or care, or any person who has knowledge of the incident, jointly with any of the above.
5. Where the aggrieved person for any other reason is unable to make a complaint, a complaint may be filed by any person who has knowledge of the incident, with her written consent.
6. Where the aggrieved person is dead, a complaint may be filed by any person who has knowledge of the incident, with the written consent of her legal heir.
Manner of Inquiry:
1. On receipt of complaint, the ICC shall intimate the date, time and place of the hearing of the complaint to the Complainant and the Respondent.
2. At the time of filing the complaint, the Complainant shall submit to the ICC six copies of the complaint, along with supporting documents and names and addresses of witnesses, if any.
3. On receipt of such complaint, the ICC shall provide one copy of such complaint to the Respondent within 7 working days.
4. The Respondent shall file his reply along with a list of documents, names and addresses of witnesses, within 10 working days of receipt of the complaint.
5. The ICC shall investigate in detail into the complaint using procedures in conformity with the principles of natural justice.
6. The ICC shall provide reasonable opportunity to the Complainant and the Respondent to present and defend her/his case.
7. The ICC shall have the right to summon as many times the Complainant, or the Respondent against whom the complaint is made, or aggrieved any other witnesses for the purpose of supplementary testimony or any clarification.
8. The ICC shall have the right to terminate the enquiry or to give an ex-parte decision on the complaint, if the Respondent or Complainant fails to be present for 3 consecutive hearings, without sufficient cause. Such termination or ex-parte order may not be passed without giving a notice in writing 15 days in advance to the concerned party.
9. A quorum of 3 members is required to be present for a proceeding to take place. The ICC shall meet every quarter to ensure effective implementation of the policy and to monitor effective/timely redressal of complaints if any.
10. The parties shall not be allowed to bring any legal practitioner to represent them in their case at any stage of the proceedings before the ICC.
11. The ICC must complete its investigation within a period of 90 days.
Conciliation:
1. At the request of the Complainant, the ICC, before initiating an enquiry, shall take steps to assist the parties settle the matter through conciliation, provided that no monetary settlement shall be made a basis of such conciliation.
2. Where the parties have arrived at a settlement, the ICC shall record the settlement so arrived and forward the same to the employer/management of the Organisation.
3. The ICC shall also provide a copy of the same to the Complainant and the Respondent and no further enquiry shall be conducted by the ICC.
Disciplinary Action:
On arriving at the conclusion that the allegation against the Respondent is true, the ICC shall make recommendations to the employer/management of the Organisation to take either one or combined action as given below, based on the impact of the harassment on the Complainant:
1. Obtain a written apology from the Respondent
2. Warn, reprimand or censure the Respondent
3. Withhold promotion of the Respondent
4. Withhold increments of pay of the Respondent
5. Terminate the Respondent from the service of the Organisation
6. Compel the Respondent to pay a reasonable amount of compensation to the Complainant, and in case the Respondent fails to pay the amount, the same may be deducted from his salary every month
7. In case of contractual employees, the committee may recommend:
  1. Termination of contractual services with the Respondent and that the agency replace the employee
  2. Warning and taking a written bond of good conduct from the Respondent employee and the agency
  3. Compel the Respondent to pay a reasonable amount of compensation to the Complainant
8. Where an outsider or visitor is the perpetrator, in addition to assisting the Complainant to initiate action under the Indian Penal Code of 1860, or any other law for the time being in force, the employer/management of the Organisation may pass and implement necessary orders restricting, the perpetrator’s entry into the premises and forewarn him of criminal/legal action in case any trauma is caused to the Complainant, then or thereafter.
Determination of Compensation:
Shall be based on the following -
1. Mental trauma, pain, suffering and emotional distress caused to the Complainant;
2. Loss in career opportunity due to the incident of sexual harassment;
3. Medical expenses incurred by the Complainant for physical and psychiatric treatment;
4. Income and financial status of the Respondent;
5. Feasibility of such payment in lump sum or in installments.
6. The employer/ management of the Organisation shall act upon the final recommendations of the ICC, within 60 days of its receipt of the recommendation.
False and Malicious Complaint:
1. If the ICC finds that the allegation against the Respondent is done with malicious intent by the Complainant/witnesses respectively, or if the Complainant/witnesses produced forged or misleading documents, the ICC shall recommend to the employer/management of the Organisation to take suitable action to prevent recurrence and those others are dissuaded from raising such false complaints.
2. Provided, that mere inability to substantiate a complaint, or to provide adequate proof of sexual harassment, need not attract action against the Complainant and further, that the malicious intent of the Complainant shall be established after an inquiry in accordance with the procedure prescribed above.
Protection against Victimization:
The following will be the obligations of the Company, during the processing/ investigation of the Compliant:
1. In the event the Respondent is the Complainant’s Reporting Manager/ senior, the Company will review the possibility of relocating the employee within the Company and ensure that the Complainant is not being evaluated by the Respondent.
2. Ensure that any sort of retaliation against the Complainant or witnesses, is strictly prohibited. Any act of reprisal, including internal interference, coercion and restraint by the Respondent, whether directly or indirectly, will result in appropriate action against the Respondent by the ICC, in consultation with the Management.
3. In case the Respondent is a third party interacting with the company, such respondent shall not be allowed to enter the company premises except for the purpose of attending any meeting/ interaction as and when required by the ICC.
4. Post conclusion of the investigations of the complaint, the Company will observe the following:
  1. If the Respondent is found to be guilty, the Respondent shall not write the evaluation/ reports of the Complainant, if he is otherwise authorized to do so.
  2. In case the Respondent is a third party interacting with the company and found to be guilty, the Respondent shall not be allowed to enter the Company premises.
Confidentiality:
1. The contents of the complaint made, the identity and address of the aggrieved person, the Respondent and any witnesses, any information relating to the conciliation and inquiry proceedings, recommendations of the ICC, and the action taken by the employer, shall not be published, communicated or made known to the public, press or media in any manner, provided
2. that information may be disseminated regarding the justice secured by any victim of sexual harassment.
3. The Organisation shall recover a sum of Rs.5000.00 (five thousand rupees) as penalty from any person who violates the confidentiality obligation under this Policy, apart from other disciplinary action.

Duties of the Employer
1. Provide a safe working environment at the workplace, which shall include safety of women coming into contact with men, at the workplace;
2. Display at any conspicuous place in the workplace, the penal consequences of sexual harassment; and the order constituting the ICC;
3. Declare names and contact details of all members of the ICC;
4. Organize workshops and awareness programs at regular intervals to sensitize employees with the provisions of the Act and to conduct orientation programs for members of the ICC;
5. Provide necessary facilities to the ICC to deal with a complaint and to conduct an inquiry;
6. Assist in securing the attendance of the Respondent and witnesses before the ICC;
7. make available such information to the ICC with regard to the complaint;
8. Provide assistance to the complainant if she chooses to file a complaint against the Respondent in relation to a sexual harassment offence under the IPC or any other law for the time being in force;
9. Treat sexual harassment as misconduct under the Organisation’s code of conduct and to initiate action when such misconduct occurs;
10. Monitor the timely submission of the Annual Report by the ICC
Additional Security Initiatives for women employees of Company
1. Where Company is legally advised that any incident of sexual harassment constitutes a criminal offence, Company will inform the relevant authority, provide full details and request appropriate action. If the aggrieved woman directly takes any action, against the Respondent, either civil or criminal, the ICC, on becoming aware of such action by the complainant, shall be entitled to, suo moto, start the internal enquiry / investigation and recommend appropriate action.
2. Company will ensure that the career interests of the Complainant are not adversely affected by virtue of the individual having drawn attention to an incident of sexual harassment.
3. If the ICC receives an anonymous reference related to sexual harassment, it will draw the attention of the H R Manager concerned with the relevant location. The matter will be fully examined by the concerned H R Department and the conclusions and plans for necessary action will be communicated to the ICC.
4. Heads of departments and senior management at all Company locations will be expected to be sensitive to any circumstances or behaviour among their colleagues, which appear to go against the Organization’s policy on this matter. In case they become aware of any such incidence, they will immediately inform the head of the ICC and take appropriate action.
5. When attending work related social events, meetings, dinners, etc. outside of office hours, women employees should try and have another Company team member accompany them, if possible. Team members must inform their Line Manager of any such events they plan to attend.
6. Team members must use sound judgment when socializing with external contacts developed through work initiatives.
7. Team members travelling on Company work must inform their Line Manager of the dates, duration, location, and purpose of the visit. Contact information for the partner organization must be documented and provided to the Line Manager.
8. Women employees/fellows/interns catching up after office hours in their personal capacities have to be careful and should take care of themselves, as Company will have no control over any incidents or accidents that may occur after office hours.
9. As a representative of Company, each staff is expected to act responsibly and respectfully both within and outside the office and during and beyond office hours.
Document Alteration
1. This document shall be altered to be in line with the Act and such alterations shall be intimated to the employees.