Introduction

As an organization, Red Road is committed to ensuring that the work environment is conducive to fair, safe and harmonious relation between employees. Discrimination and harassment of any type is strictly prohibited.

We have also ensured that no employee is disadvantaged by way of gender discrimination. We would however, like to now ensure that there is absolute clarity on the important and sensitive issue of sexual harassment. This note therefore annunciates the Company’s approach to the issue of sexual harassment and its policy for dealing with any incidence of the same.

Scope of the Policy

• This policy applies to all individuals who are employed as permanent, temporary, trainees, interns, probationary and on contract role at any business location of the company.

• An alleged act of sexual harassment, whether the incident has occurred during or beyond office hours which includes telecons after office hour, business trips, business meetings and business- related social events.

• This policy is only applicable when both or the alleged harasser & the complainant are employees of the company.

Definition of issue

A broad definition of Sexual harassment consists of any physical or verbal behavior and any form of communication that has unnecessary, improper or unwelcome sexual connotations. Sexual harassment may vary in form depending on circumstances. It may consist of, but not be limited to, any of the following:

• Unwelcome sexual advances, request for sexual favors, display of sexual visuals, sexual audios, pornographic or obscene material and any other verbal or physical conduct of a sexual nature.

• Transmitting any message, by mail, telephone, e-mail etc. which is obscene, lewd, suggestive or blatantly sexual in nature.

• Any explicit or implicit communication wherein a sexual favor or demand, whether by words or action, is made a condition for an individual's employment, career progress, promotion etc. thereby creating a hostile environment.

• Sexually charged jokes or remarks and behavior which have sexually oriented innuendoes.

• Consistent pattern of unnecessary physical contact, staring or targeting unreasonable attention at an individual in day-to-day dealings.

• Any pervasive pattern of behavior which makes employees uncomfortable, insecure or feel humiliated or disadvantaged based on gender differentiation.

• Actual sexual assault

  
  

As mentioned above, this is an indicative but not an exhaustive list of possible forms of sexual harassment.

Red Road policy on sexual harassment

The company policy is to totally prohibit any form of sexual harassment in the way employees behave with each other. This would also include complaints relating to instances outside of the workplace this applies equally to relations between superior and subordinates as well as between peers. Any incident of sexual harassment will be viewed extremely serious. A complaint or report of sexual harassment will be immediately investigated, and appropriate action will be taken against the offending employee or employees. Such action will depend on the nature and seriousness of the offense and will include strict disciplinary action including termination of services.

Process for dealing with incidents of sexual harassment

Any employee who experiences sexual harassment can get in touch with any member of the Internal Complain Committee who’s contact details are provided in Annexure 1 for convenient and confidential access. Alternatively, the affected employee may approach any Senior Manager, BU head or HR manager and such person will inform a member of the Committee immediately.

On receipt of such complaint, the Committee will immediately arrange to fully investigate all relevant details of the matter. It will do so with all possible care, sensitivity and discretion in protecting the sensibilities of the affected employee. The employee or employees, who have allegedly committed the offense, would be given all reasonable opportunities to be heard by the committee.

The result of this investigation will be formally recorded and communicated to the President, Red Road, along with the recommendation for appropriate action.

The committee will normally complete this process and make it formal recommendation within 20 days after receiving the complaint, unless there are exceptional circumstances.

Process of making a complaint:

Any aggrieved woman employee may make in writing/e-mail, a complaint of sexual harassment at workplace to the ICC panel within a period of one months from the date of incident and in case of a series of incidents, within a period of one month from the date of the last incident.

Provided that where such complaint cannot be made in writing, the Presiding Officer or any member of the ICC panel, shall render all reasonable assistance to the woman for making the complaint in writing.

Provided further that the Internal Complain Committee, for the reasons to be recorded in writing, extend the time limit not exceeding one months, if it is satisfied that the circumstances were such which prevented the woman from filing a complaint within the said period.

Depending upon the nature of the Complaint, the Core Complaints Committee may direct that a Conciliation/Investigation be conducted by an Investigating Committee constituted by the Internal Complaints Committee.

In case of conciliation

The Internal Complaint Committee may not order an investigation, if in the initial stage of enquiry complainant withdraws the complaint arrives at a conclusion of Conciliation process. This conciliation process will not involve any monetary settlement.

In either case, Investigating Committee shall provide an opportunity to the complainant as well as the alleged harasser to represent their position and provide their explanations.

Where a settlement has been arrived at in the conciliation process, the internal committee will provide the copies of the settlement arrived at after the conciliation process to the complainant as well the alleged harasser.

In case of an enquiry into complaint

In the event, an investigation is found to be necessary; the following procedure shall be adopted by the Committee:

For the purpose of making an investigation, the Internal Committee shall have the power as mentioned below

• Summoning and enforcing the attendance of any person

• Requiring the discovery and production of documents

• Any other matter which may be prescribed.

If the Complainant desires to tender any documents by way of evidence before the Committee, she / he shall supply original copies of such documents. Similarly, if the person against whom complaint is made desires to tender any documents in evidence before the Committee, he / she shall supply original copies of such documents. Both shall affix his / her signature on the respective documents to certify these to be original copies.

• Written record of all discussions is to be maintained by the committee

• The investigation shall be completed within a maximum period of 15 working days.

• Where the Internal Complaint Committee, arrives at the conclusion that the allegation against the alleged harasser has been proved, it shall take necessary disciplinary actions.

• Where the Internal Committee, arrives at a conclusion that during the investigation any witness has given false evidence or produced any forged or misleading document, it may recommend, to take strict

• disciplinary action. Some of them would be – show cause notice, suspension, stoppage of increment, demoting the employee, Termination etc.

• The final decision shall be communicated to the complainant and the alleged harasser in both the instances above.

Function of Investigation Committee

To notify in writing/email the time and dates of the meetings to be held to the complainant and the alleged harasser.

• A copy of the statement of complaint to be given to the alleged harasser with reasonable time to study the same prior to appearing before the committee appointed for this purpose

• Appropriate recordings of each enquiry sitting, and observations shall be made by the committee members.

• The conclusion of the findings and report to be handed over to the Presiding officer of the ICC. Conclusion of the findings will also be informed to both the parties concerned.

Disciplinary action:

Possible Disciplinary actions which can be taken against the alleged harasser:

• A letter of warning that will be placed in the personal file of the harasser.

• Stoppage of increment or promotion

• Demotion

• Termination/dismissal from the services of the Company.

• Any other disciplinary action that the ICC panel may deem fit.

Annexure 1

Internal Complaints Committee

The Company has established an Internal Complaints Committee for Sexual Harassment consisting of six internal members and one external member. The names of the members of this Committee and their contact details are given below.

External Representative: