Objective:

Vasudha Pharma Chem Limited henceforth will be referred to as 'Organization' for this policy purpose. Our Organization is committed to provide a work environment that ensures every employee both women and men are treated with dignity and respect and afforded equitable treatment. The Organization is also committed to promote a work environment that is conducive to the professional growth of its employees and encourages equality of opportunity.

The Organization 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.

Scope:

This policy applies to all categories of employees of the Organization, including permanent management and workmen, temporaries, trainees and employees on contract at its workplace or at client sites. The Organization 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 Organization's business is conducted.
• All Organization related activities performed at any other site away from the Organization's premises.
• Any social, business or other functions where the conduct or comments may have an adverse impact on the workplace or workplace relations.

Date of Commencement:

This policy will continue in operation with effect from 01st Jan, 2018

First amendment: 01st Feb, 2019 and is effected from 01st Mar, 2019

Second amendment: 05th Mar 2022 and is effective from 07th Mar, 2022

Third amendment: 05th Mar 2024 and is effective from 07th Mar, 2024

Definitions:

Sexual harassment may be one or a series of incidents involving unsolicited and unwelcome sexual advances, requests for sexual favors, or any other verbal or physical conduct of sexual nature (whether directly or by implication) namely:

• Physical contact and advances; or
• A demand or request for sexual favours, such as seeking sexual favours or advances in exchange for work benefits or refusal to comply with a 'request' is met with retaliatory action such as dismissal, demotion, difficult work conditions; or
• Sexually coloured remarks; or
• Showing pornography; or
• Entry into a private place marked for woman, with the intent to commit mischief and harassment;

Sexual Harassment at the workplace includes:

• Taking photographs of aggrieved woman/man without permission and converting it into pornographic material and/or circulating the same by means of electronic media;
• Any other unwelcomed physical, verbal or non-verbal conduct of sexual nature; including eve-teasing, gender based insults or sexist remarks, unwelcome sexual overtone in any manner, like obnoxious telephone calls, touching or brushing against any part of the body, displaying pornographic or other offensive or derogatory pictures, cartoons, pamphlets or sayings, forcible physical touch or molestation.

The following circumstances, among other circumstances, if it occurs or is present in relation to or connected with any act or behavior of sexual harassment may amount to sexual harassment:

• Implied or explicit promise of preferential treatment in her/him employment, or
• Implied or explicit threat of detrimental treatment in her/him employment;
• Implied or explicit threat about her/him present or future employment status; or
• Interference with her/him work or creating an intimidating or offensive or hostile work environment for her/him;
• Humiliating treatment likely to affect her/him health or safety.

Sexual harassment shall also include such unwelcome sexually determined behavior by any person either individually or in association with other persons or by any person in authority whether directly or by implication which amounts to offence defined in the Indian Penal Code.

Aggrieved woman: In relation to a workplace, a woman, of any age, whether employed or not, who alleges to have been subjected to any act of sexual harassment by the respondent that includes contractual, temporary and visitors.

Aggrieved man: In relation to a workplace, a man, of any age, whether employed or not, who alleges to have been subjected to any act of sexual harassment by the respondent that includes contractual, temporary and visitors.

Respondent: A person against whom a complaint of sexual harassment has been made by the aggrieved woman/man.

Employee: A person employed at the workplace, for any work on regular, temporary, ad-hoc or daily wage basis, either directly or through an agent, including a contractor, with or without the knowledge of the principal employer, whether for remuneration or not, or working on a voluntary basis or otherwise, whether the terms of employment are express or implied and includes a coworker, a contract worker, probationer, trainee, apprentice or by any other such name

Employer: A person responsible for management, supervision and control of the workplace

Workplace: Workplace: Premises, locations, establishments, enterprises, institutions, offices, branches or units. established, subsidiaries which are controlled by the Company. Places visited by the Employee arising out of or during the course of employment including official events, accommodation and transportation provided by the employer for undertaking a journey.

Responsibilities regarding Sexual Harassment:

All employees of the Organization have a personal responsibility to ensure that their behavior is not contrary to this policy. All employees are encouraged to reinforce the maintenance of a work environment free from sexual harassment.

Complaint Mechanism:

Whether or not such conduct constitutes an offence under law or a breach of the service rules, an appropriate complaint mechanism in the form of "Complaints Committee" has been created in the Organization for time-bound redressal of the complaint made by the victim.

Complaints Committee:

Internal Complaints Committee (ICC):

• The Company shall constitute an Internal Complaints Committee (ICC) -also known as the POSH Committee. If the administrative units of a company are located at different places, the ICC shall be constituted at all administrative units or offices covering each of its administrative offices and units.
• The committee at each location comprises of:
  • Presiding Officer: A woman employed at a senior level in the organization or workplace.
  • At least 2 members from amongst employees, committed to the cause of women and or having legal knowledge
  • One external member, familiar with the issues relating to sexual harassment
  • At least one half of the total members is women
• The committee is responsible for:
  • Receiving complaints of sexual harassment at the workplace
  • Initiating and conducting inquiry as per the established procedure
  • Submitting findings and recommendations of inquiries
  • Coordinating with the employer in implementing appropriate action
  • Discouraging and preventing employment-related Sexual Harassment
  • Maintaining strict confidentiality throughout the process as per established guidelines
  • Submitting annual reports in the prescribed format
• The Presiding Officer and every member of the ICC shall hold office for a period not exceeding three years, from the date of their nomination. A member of the ICC may resign at any time by tendering his/her resignation in writing to the Company.
• The Organization has instituted a Complaints Committee for redressal of sexual harassment complaint (made by the victim) and for ensuring time bound treatment of such complaints.

Current nominated members of the committees are given in Annexure A.

• Meetings of the ICC to be held:
  • Every quarter
  • Within 7 (seven) days from receipt of Complaint
  • Such other special meetings to address the Complaints pertaining to sexual harassment of the female employees.
• It shall prepare an annual report in each calendar year and submit the same to the Employer and the District Officer which shall have the following details:
  • Number of complaints of sexual harassment received in the year
  • Number of complaints disposed off during the year
  • Number of cases pending for more than ninety days
  • Number of workshops or awareness programmes against sexual harassment carried out
  • Nature of actions taken by the Employer
• In conducting the inquiry, a minimum of three members of the ICC including the Presiding Member shall be present.

PROCEDURES FOR RESOLUTION, SETTLEMENT OR PROSECUTION OF ACTS OF SEXUAL HARASSMENT:

The Organization is committed to providing a supportive environment in which to resolve concerns of sexual harassment as under:

A. Informal Resolution Options:

• 1. When an incident of sexual harassment occurs, the victim of such conduct can communicate her/him disapproval and objections immediately to the harasser and request the harasser to behave decently.
• 2. If the harassment does not stop or if victim is not comfortable with addressing the harasser directly, she/he can bring her/his concern to the attention of the Complaints Committee for redressal of her/him grievances. The Complaints Committee will thereafter provide advice or extend support as requested and will undertake prompt investigation to resolve the matter.

B. Complaints:

• 1. Any employee with a harassment concern, who is not comfortable with the informal resolution options or has exhausted such options, may make a formal complaint to the Chairperson of the Complaints Committee constituted by the Management. The complaint shall have to be in writing and can be in form of a letter, preferably within 15 days from the date of occurrence of the alleged incident, sent in a sealed envelope. Alternately, the employee can send complaint through an email. The employee is required to disclose her/his name, department, division and location she/he is working in, to enable the Chairperson to contact her/him and take the matter forward.
• 2. The Chairperson of the Complaints Committee will proceed to determine whether the allegations (assuming them to be true only for the purpose of this determination) made in the complaint fall under the purview of Sexual Harassment, preferably within 30 days from receipt of the complaint. In the event, the allegation does not fall under the purview of Sexual Harassment or the allegation does not mean an offence of Sexual Harassment, she will record this finding with reasons and communicate the same to the complainant.
• 3. If the Chairperson of the Complaints Committee determines that the allegations constitute an act of sexual harassment, she will proceed to investigate the allegation with the assistance of the Complaints Committee.
• 4. Where such conduct on the part of the accused amounts to a specific offence under the law, the Organization shall initiate appropriate action in accordance with law by making a complaint with the appropriate authority.
• 5. The Complaints Committee shall conduct such investigations in a timely manner and shall submit a written report containing the findings and recommendations to the Corp. Head - MW & Corp. Head HR & IR as soon as practically possible and in any case, not later than 90 days from the date of receipt of the complaint. The Corp. Head - MW & Corp. Head - HR will ensure corrective action on the recommendations of the Complaints Committee and keep the complainant informed of the same.
• 6. Resolution procedure through conciliation: Once the complaint is received, before initiating the inquiry, the committee may take steps to conciliate the complaint between the complainant and the respondent. This is only if requested by the aggrieved woman. No monetary settlement can be made as a basis of conciliation. In case a settlement is arrived at, the committee records & reports the same to the employer for taking appropriate action. Resolution through conciliation is to happen within 2 weeks of receipt of complaint.
• 7. Termination of Inquiry: Committee may terminate the inquiry or give ex-parte decision, if complainant or respondent respectively is absent for 3 consecutive hearings, without sufficient reason. 15 day written notice is to be given to the party, before termination of enquiry or ex-parte order.
• 8. Action to be taken after inquiry: Post the inquiry, the committee submits its report containing the findings and recommendations to the employer, within 10 days of completion of the inquiry.
• 9. Complaint unsubstantiated: Where the committee arrives at the conclusion that the allegation against the respondent has not been proved, it recommends to the employer that no action is required to be taken in this matter. Further, the committee ensures that both parties understand that the matter has been fully investigated, that the matter is now concluded, and neither will be disadvantaged within the Company.

C. Corrective action may include any of the following:

Complaint substantiated: Where the committee arrives at the conclusion that the allegation against the respondent has been proved, it recommends to the employer to take necessary action for sexual harassment as misconduct in accordance with the applicable service rules and policies, and this may include:

• a. Formal apology
• b. Counseling
• c. Written warning to the perpetrator and a copy of it maintained in the employee's file.
• d. Change of work assignment / transfer for either the perpetrator or the victim.
• e. Suspension or termination of services of the employee found guilty of the offence.
• f. In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for appropriate disciplinary action by the Management.

Confidentiality:

The Organization 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 any investigatory process to the extent practicable and appropriate under the circumstances.

Access to Reports & Documents:

All records of complaints, including contents of meetings, results of investigations and other relevant material will be kept confidential by the Organization except where disclosures required under disciplinary or other remedial processes.

Protection to Complaint/Victim:

The Organization 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 Organization will ensure that 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.

Malicious Allegations:

Where the committee arrives at the conclusion that the allegation against the respondent is malicious or the aggrieved woman/man or any other person making the complaint has made the complaint knowing it to be false or the aggrieved woman/man or any other person making the complaint has produced any forged or misleading document, it may recommend to the employer to take action against the woman/man or the person making the complaint. The action recommended should be similar to the ones proposed for the respondent in case of substantiated complaints. While deciding malicious intent, the committee should consider that mere inability to substantiate a complaint need not mean malicious intent. Malicious intent must be clearly established through a separate inquiry.

Appeal:

Any party not satisfied or further aggrieved by the implementation or non-implementation of recommendations made, may appeal to the appellate authority in accordance with the Act and rules, within 90 days of the recommendations being communicated.

Roles and Responsibilities:

Employee:

• Participate in the POSH programme
• Seek clarification on POSH including what constitutes Sexual Harassment
• Understand the process of giving complaint
• Support the fellow employee if she/he is sexually harassed
• Acknowledgement that the policy is understood

Management:

• Encourage employees to attend the POSH Awareness programme
• Clarify doubts on POSH
• Address employees’ concern on POSH
• Support employees if they are sexually harassed

Human Resources:

• Organise Awareness programmes on POSH
• POSH policy to be displayed in the Notice board and intranet
• Annual Refresher programme on POSH
• Acknowledgement from all employees that they have understood the POSH Policy
• File acknowledgement from employees in their personal file

Legal Compliance:

The ICC shall in each calendar year prepare, is such format as may be prescribed, an annual report and submit the same to the employer and the District Officer (as defined in the Act). The report shall have the following details:

• number of complaints of Sexual harassment received in the year
• number of complaints disposed of during the year
• number of cases pending for more than 90days
• number of workshops or awareness program against Sexual Harassment carried out
• nature of action taken by the employer or District Officer

Conclusion :

In conclusion, the Organization reiterates its commitment to providing its employees both women and men, a workplace free from harassment/ discrimination and where every employee is treated with dignity and respect.

Power to Amend:

The Organization reserves the right to amend the policy at any time without assigning any reason whatsoever. The utility and interpretation of the policy will be at the sole discretion of the Management.

Date of Review: 05th Mar, 2024

Next date of Review: 04th Mar, 2026

Female Representatives to be nominated under the policy of Prevention of Sexual Harassment of Women at Workplace.

Date of amendment: 05.03.2024

Effective date of Implementation: 07.03.2024

ANNEXURE-A

S#	Location	Name	Department	Position
1	Corporate Office	Mrs. D.Annapurna	Accounts	Presiding Officer
2		Mr. Rabindra Kumar	CS	Internal Member
3		Mr Allanka Ravikanth	HR & IR	Internal Member
4		Mrs. Pamarthy Padmavathi	POSH Enabler	External Member
1	Unit-I	Mrs. D Pavani	QC	Presiding Officer
2		Mr K Sathaiah	Manufacturing-Head	Internal Member
3		Mrs. P R Bhavani	QA	Internal Member
4		Mrs. Pamarthy Padmavathi	POSH Enabler	External Member
1	Unit-II	Mrs. Dantuluri Sujatha	HR & IR	Presiding Officer
2		Mr P V Suresh Varma	Manufacturing Head	Internal Member
3		Ms G Kumari	HR & IR	Internal Member
4		Mrs. Pamarthy Padmavathi	POSH Enabler	External Member
1	Unit-III	Mrs. Dantuluri Sujatha	HR & IR	Presiding Officer
2		Mr. K Rama Murthy	Manufacturing-Head	Internal Member
3		Mr D Venkata Ramana	Production	Internal Member
4		Mrs. Pamarthy Padmavathi	POSH Enabler	External Member
1	Unit-IV	Mrs. Dantuluri Sujatha	HR & IR	Presiding Officer
2		Mr P Ramu	Manufacturing-Head	Internal Member
3		Mrs N. Bharati	F R&D	Internal Member
4		Mrs. Pamarthy Padmavathi	POSH Enabler	External Member
1	Unit-V	Mrs. Dantuluri Sujatha	HR & IR	Presiding Officer
2		Mr. S A Pillai	Manufacturing-Head	Internal Member
3		Mr. D Vamsikrishna Varma	HR & IR	Internal Member
4		Mrs. Pamarthy Padmavathi	POSH Enabler	External Member
1	R&D	Mrs. Dantuluri Sujatha	HR & IR	Presiding Officer
2		Mr Gopi	IPR	Internal Member
3		Mr. Y Satish	HR & IR	Internal Member
4		Mrs. Pamarthy Padmavathi	POSH Enabler	External Member

Note: If anyone from above mentioned positions (left from organization or transfer to other locations) new member will nominated for the respective positions. The same will be updated in the next policy review.